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Michigan Court of Appeals - Unemployment Agency: Case Brief









For Publication

No. 361919


Opinion by SWARTZLE, J.

Lower Court Name, No. & Rulings:

Jackson Circuit Court, LC No. 21-003433-AE

Clinton Circuit Court, LC No. 21-012118-AE

The lower courts upheld the decisions of the Administrative Law Judges, which were in favor of the claimants.

Case Summary:

The case involves two consolidated appeals where the claimants, Amanda Holbrook and Ashleigh Baker, were initially denied or had their unemployment benefits rescinded by the Michigan Unemployment Insurance Agency. Both claimants appealed, and Administrative Law Judges found them to be "covered individuals" eligible for benefits under the CARES Act due to the COVID-19 pandemic. The Agency's appeals were denied, and the circuit courts upheld the ALJ's decisions.

Areas of Law:

  • Administrative Law

  • Unemployment Benefits

  • Statutory Interpretation

Legal Issues:

  • Whether the claimants were "covered individuals" eligible for pandemic-unemployment assistance under the CARES Act.

  • Whether the Agency's argument that the claimants were not unemployed due to the COVID-19 pandemic was valid.

  • Whether the Agency waived its argument that the claimants were not "otherwise able to work and available to work."

Facts in Chronological Order:

  1. Claimants applied for unemployment benefits during the COVID-19 pandemic.

  2. The Agency denied or rescinded benefits based on its determinations.

  3. Claimants appealed, and ALJs found in favor of the claimants.

  4. Agency appealed to the circuit courts, which upheld the ALJ's decisions.

  5. Agency appealed to the Michigan Court of Appeals.


The Court of Appeals affirmed the circuit courts' decisions, supporting the claimants' eligibility for benefits under the CARES Act.

Explain if the Court “Got it Right”:

The Court of Appeals conducted a de novo review of the statutory interpretation and found that the claimants met the criteria of "covered individuals" under the CARES Act. The court also noted that the Agency waived its argument regarding the claimants' ability to work by not raising it earlier in the proceedings. The court's affirmation of the lower courts' decisions appears to be well-reasoned and supported by the evidence and applicable law.

Michigan Courtroom

Cases by Name Include:

  1. Tolas Oil & Gas Exploration Co v Bach Servs & Mfg, LLC, ___ Mich App ___, ___; ___ NW2d ___ (2023) (Docket No. 359090)

  2. Booth v Univ of Michigan Bd of Regents, 444 Mich 211, 234 n 23; 507 NW2d 422 (1993)

  3. Michigan Ambulatory Surgical Ctr v Farm Bureau General Ins Co of Michigan, 334 Mich App 622, 632; 965 NW2d 650 (2020)

  4. Mangiero v Comm’r of Labor, 197 AD3d 1458; 153 NYS3d 696 (NY S Ct, 2021)

  5. Hodge v US Security Assoc, Inc, 497 Mich 189, 193-194; 859 NW2d 683 (2015)

  6. Lawrence v Mich Unemployment Ins Agency, 320 Mich App 422, 431; 906 NW2d 482 (2017)

  7. Liss v Lewiston-Richards, Inc, 478 Mich 203, 207; 732 NW2d 514 (2007)

  8. Griffin v Griffin, 323 Mich App 110, 120; 916 NW2d 292 (2018)

  9. McQueer v Perfect Fence Co, 502 Mich 276, 286; 971 NW2d 584 (2018)

MCL’s Cited Include:

  • 15 USC 9021(a)(3)(A)

MCR’s Cited Include:

  • None

Tags for Case:

  • COVID-19

  • CARES Act

  • Unemployment benefits

  • Covered individual

  • Michigan Unemployment Insurance Agency

  • Administrative Law Judge

  • Waiver

  • Statutory interpretation

SEO Keywords for Case:

  • CARES Act eligibility

  • Unemployment benefits COVID-19

  • Michigan unemployment claims

  • Administrative law appeals

  • Pandemic unemployment assistance

  • Legal interpretation CARES Act

  • Unemployment benefits appeal Michigan

  • COVID-19 unemployment benefits litigation

  • CARES Act covered individual definition


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