Paratransit, Inc. v. CUIAB, 2014 WL 2988013 (Cal. S. Ct. 2014)

Craig Medeiros worked as a vehicle operator for Paratransit for six years. Medeiros was a member of a union, and the union and the employer were parties to a collective bargaining agreement. Paratransit investigated a complaint filed by a passenger, alleging that Medeiros had unlawfully harassed her. Following the investigation, Paratransit concluded the alleged misconduct had occurred and decided to suspend Medeiros for two days without pay. Medeiros denied the misconduct and refused to sign a memorandum documenting the discipline (but not admitting guilt), stating his belief that by signing the memorandum he would be admitting guilt. He also requested that a union representative be present during his meeting with Paratransit, a request the employer denied. Paratransit subsequently terminated Medeiros for insubordination due to his refusal to sign the disciplinary notice. While the lower courts found that Medeiros had engaged in misconduct by deliberately disobeying Paratransit’s lawful and reasonable instruction to sign the disciplinary notice, the California Supreme Court reversed, holding that Medeiros was not disqualified from receiving unemployment benefits. The Supreme Court concluded Medeiros “acted out of a genuine belief that signing the notice would be an admission of allegations he disputed, and that belief was not so unreasonable under the circumstances as to constitute misconduct within the meaning of the [California Unemployment Insurance Code].”