Ohio Bureau of Employment Services v. Hodory

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Ohio Bureau of Employment Services v. Hodory
Reference: 431 U.S. 471
Term: 1977
Important Dates
Argued: February 28, 1977 Decided: May 31, 1977
Outcome
United States District Court for the Northern District of Ohio reversed
Majority
Warren Burger • Lewis Powell • Thurgood Marshall • William Brennan • Potter Stewart • Byron White • Harry Blackmun • John Stevens Justice William Rehnquist did not take part in the consideration or decision of the case.

Ohio Bureau of Employment Services v. Hodory was a case decided on May 31, 1977, by the United States Supreme Court in which the court ruled that Ohio could deny unemployment insurance benefits to Leonard Hodory since he was laid off due to a nationwide strike at his employer's coal mines. The Supreme Court reversed the lower court and held that the Ohio law allowing for unemployment insurance disqualifications for certain labor disputes did not violate federal law. The court The court found that the Ohio law had a rational purpose aimed at upholding the fiscal integrity of the state’s unemployment insurance program, so the denial of benefits did not violate the due process or equal protection clauses of the Fourteenth Amendment.

Background

Leonard Hodory worked for the United States Steel Corporation (USS), which furloughed Hodory after his plant was shut down due to a fuel shortage related to a nationwide strike at USS's coal mines. Hodory applied for unemployment insurance benefits, but the Ohio Bureau of Employment Services rejected his claim. The bureau argued that Ohio law prevented Hodory from claiming benefits because his unemployment was "due to a labor dispute other than a lockout at any factory ... owned or operated by the employer by which he is or was last employed."

Hodory filed suit in the United States District Court for the Northern District of Ohio, alleging Ohio's law conflicted with provisions of the Social Security Act (SSA). Hodory also said the law, as applied, lacked a valid public purpose or rationale, in violation of the Equal Protection and Due Process clauses of the Fourteenth Amendment.

The district court ruled the law violated the Fourteenth Amendment, as applied.

Oral argument

Oral argument was held on February 28, 1977. The case was decided on May 31, 1977.

Decision

The Supreme Court decided 8-0 that Ohio Revenue Code Annotated Section 4141.29(D)(1)(a) (1973) did not conflict with sections 303(a)(1) and (3) of the Social Security Act of 1935 or 42 U.S.C. sections 503(a)(1) and (3). The court also ruled that the Ohio law did not violate the Due Process or Equal Protection clauses of the Fourteenth Amendment. Justice Harry Blackmun delivered the opinion of the court, joined by Chief Justice Warren Burger and Justices Lewis Powell, Thurgood Marshall, William Brennan, Potter Stewart, Byron White, and John Stevens. Justice William Rehnquist did not take part in the consideration or decision of the case.

Opinions

Opinion of the court

Justice Harry Blackmun, writing for the court, argued Ohio Revenue Code Annotated Section 4141.29(D)(1)(a) (1973) did not conflict with sections 303(a)(1) and (3) of the Social Security Act of 1935 or 42 U.S.C. sections 503(a)(1) and (3). Blackmun argued in part that since Congress had not passed legislation specific to labor dispute disqualifications, states had the freedom to pass such laws. He also held that the state had a rational and valid public purpose for the law aimed at upholding the fiscal integrity of the state’s unemployment insurance program, so it did not violate the Due Process Clause or Equal Protection Clause of the Fourteenth Amendment.

“	Indeed, study of the various provisions cited shows that, when Congress wished to impose or forbid a condition for compensation, it was able to do so in explicit terms. There are numerous examples, in addition to the one set forth in n. 16, less related to labor disputes but showing congressional ability to deal with specific aspects of state plans. The fact that Congress has chosen not to legislate on the subject of labor dispute disqualifications confirms our belief that neither the Social Security Act nor the Federal Unemployment Tax Act was intended to restrict the States' freedom to legislate in this area. ... Looking only at the face of the statute, an acceptable rationale immediately appears. The disqualification is triggered by "a labor dispute other than a lockout." In other words, if a union goes on strike, the employer's contributions are not increased, but if the employer locks employees out, all his employees thus put out of work are compensated and the employer's contributions accordingly are increased. Although one might say that this system provides only "rough justice," its treatment of the employer is far from irrational. ... It is clear that protection of the fiscal integrity of the fund is a legitimate concern of the State. We need not consider whether it would be "rational" for the State to protect the fund through a random means, such as elimination from coverage of all persons with an odd number of letters in their surnames. Here, the limitation of liability tracks the reasons found rational above, and the need for such limitation unquestionably provides the legitimate state interest required by the equal protection equation. ... The District Court's opinion contains a paragraph declaring that, in addition to violating the Equal Protection Clause, the disqualification denied appellee due process. 408 F. Supp. at 1022. There is, however, no claim of denial of procedural due process, cf. Mathews v. Eldridge, 424 U. S. 319 (1976), and we are unable to discern the basis for a claim that appellee has been denied substantive due process.	”
—Justice Harry Blackmun, majority opinion in Ohio Bureau of Employment Services v. Hodory

See also

• Federalism
• Unemployment insurance
• The Hughes Court
• Supreme Court of the United States
• History of the Supreme Court

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