Estelle v. Eysinki
| Decision Date | 06 August 2014 |
| Docket Number | No. 2014–CA–0108.,2014–CA–0108. |
| Citation | 147 So.3d 1136 |
| Parties | Robert C. ESTELLE v. Curt EYSINKI, Executive Director, Louisiana Workforce Commission. |
| Court | Court of Appeal of Louisiana — District of US |
David Holman Williams, Southeast Louisiana Legal Services, New Orleans, LA, Counsel for Plaintiff/Appellant.
Cynthia Thomas Batiste, Peter George Wright, Louisiana Department of Labor, Baton Rouge, LA, Counsel for Defendant/Appellee.
James D. “Buddy” Caldwell, Attorney General, Emily G. Andrews, Assistant Attorney General, Office of the Attorney General, Baton Rouge, LA, Amicus Curiae/Attorney General of the State of Louisiana.
Court composed of Judge MAX N. TOBIAS, JR., Judge DANIEL L. DYSART, Judge ROSEMARY LEDET.
The plaintiff/appellant, Robert C. Estelle, appeals a trial court judgment upholding the constitutionality of La. R.S. 23:1600(5), in connection with his claim for unemployment benefits. After reviewing the record and applicable law, we also find that La. R.S. 23:1600(5) is rationally related to a legitimate state interest and, therefore, constitutional, thereby affirming the judgment below.
Mr. Estelle was a bellman at a hotel before he became unemployed. The Louisiana Workforce Commission (“LWC”) initially granted him unemployment compensation, based on his base-period wages that were more than double the $1,200 minimum required by law. However, Mr. Estelle administratively appealed because the agency had not taken into account the tips he had earned, which had been properly reported to the taxing authorities. The tips were more than twice the amount of his other wages. Once the LWC added in these additional earnings, it ruled Mr. Estelle ineligible for unemployment compensation because the distribution of his wages no longer satisfied the high-quarter-ratio requirement.
The LWC held a hearing in which Mr. Estelle's only challenge was to the constitutionality of La. R.S. 23:1600(5), which requires that a claimant's base period earnings be at least one and one-half times the earnings in his or her high-quarter of earnings. The Appeals Tribunal and, later, the LWC Board of Review (“the Board”) held that Mr. Estelle was ineligible to receive unemployment compensation, citing the high-quarter-ratio requirement of section 1600(5). The Board held that it “lacks jurisdiction as regards the constitutionality of any statute.”
The uncontested facts, established during a telephone hearing and entered as findings by the Board, are as follows:
The Board held that it lacked jurisdiction to consider the constitutionality of the statute and affirmed the decision of the LWC, holding that Mr. Estelle was ineligible to receive unemployment compensation, citing the high-quarter-ratio requirement of La. R.S. 23:1600(5).
Mr. Estelle filed an appeal with the Orleans Parish Civil District Court. The only issue to be decided was whether La. R.S. 23:1600(5) is constitutional. On 1 October 2013, the court rendered judgment finding that the factual findings of the Board were supported by sufficient and competent evidence and that the decision was correct as a matter of law. The court also found that La. R.S. 23:1600(5) was constitutional in that it did not deny Mr. Estelle equal protection of the laws and bore a rational relationship to a legitimate state interest, and its application was neither arbitrary nor capricious. This timely appeal followed.
Mr. Estelle accepts the factual findings of the Board of Review as correct. Thus, the only issue before the court concerns the constitutionality of La. R.S. 23:1600(5). The standard of review of a trial court's ruling declaring the constitutionality of a statute is de novo. Louisiana Mun. Ass'n v. State, 04–0227, p. 36 (La.1/19/05), 893 So.2d 809, 842–43.
Article I, § 3 of the 1974 Louisiana Constitution, the Declaration of Right to Individual Dignity, provides:
No person shall be denied the equal protection of the laws. No law shall discriminate against a person because of race or religious ideas, beliefs, or affiliations. No law shall arbitrarily, capriciously, or unreasonably discriminate against a person because of birth, age, sex, culture, physical condition, or political ideas or affiliations. Slavery and involuntary servitude are prohibited, except in the latter case as punishment for crime.
Article I, § 3 commands the courts to decline enforcement of a legislative classification of individuals in three different scenarios: (1) When the law classifies individuals by race or religious beliefs, it shall be repudiated completely; (2) When the statute classifies persons on the basis of birth, age, sex, culture, physical condition, or political ideas or affiliations, its enforcement shall be refused unless the state or other advocate of the classification shows that the classification has a reasonable basis; and (3) When the law classifies individuals on any other basis, it shall be rejected whenever a member of a disadvantaged class shows that it does not suitably further any appropriate state interest. Sibley v. Bd. of Sup'rs of Louisiana State Univ., 477 So.2d 1094, 1107 (La.1985).
The determination of a statute's constitutionality is a purely judicial function, which is constitutionally vested in the courts. La. Const. Art. V, 1. Constitutional scrutiny favors the statute. State v. Griffin, 495 So.2d 1306, 1308 (La.1986). Statutes are presumed to be valid, and the constitutionality of a statute should be upheld whenever possible. State v. Hart, 96–0599, p. 2 (La.1/14/97), 687 So.2d 94, 95 (citing Griffin, 495 So.2d at 1308 ). In adjudicating a constitutional challenge, the court must analyze and interpret the language of the constitutional provision specified by the challenger. Louisiana Mun. Ass'n v. State, 00–0374, p. 5 (La.10/6/00), 773 So.2d 663, 667. Constitutional provisions are to be construed and interpreted by the same rules as are other laws. Louisiana Dep't of Agriculture and Forestry v. Sumrall, 98–1587, p. 3 (La.3/2/99), 728 So.2d 1254, 1258.
When a law is clear and unambiguous and its application does not lead to absurd consequences, the law shall be applied as written and no further interpretation may be made in search of the intent of the legislature. La. C.C. art. 9. When the words of a law are ambiguous, their meaning must be sought by examining the context in which they occur and the text of the law as a whole. La. C.C. art. 12.
Under the general rules of statutory construction, courts begin their review with the premise that legislation is the solemn expression of legislative will, and, therefore, the interpretation of the law primarily involves the search for the legislature's intent. Cole–Miers Post 3619 V.F.W. of DeRidder v. State, Department of Revenue & Taxation, Office of Alcoholic Beverage Control, 99–2215 (La.1/19/00), 765 So.2d 312, 314. However, legislative intent is not the appropriate starting point for statutory interpretation. Rather, the appropriate starting point is the language of the statute itself. In re Louisiana Health Service and Indem. Co., 98–3034, p. 10 (La.10/19/99), 749 So.2d 610, 615.
La. R.S. 23:1600 states in pertinent part:
Mr. Estelle argues that this provision violates the equal protection clause of our constitution.
In general, statutes are presumed to be constitutional and the party challenging the validity of the statute has the burden of proving it is unconstitutional. See Soloco, Inc. v. Dupree, 97–1256, p. 3 (La.1/21/98), 707 So.2d 12, 14 ; Moore v. RLCC Technologies, Inc., 95–2621, pp. 7–8 (La.2/28/96), 668 So.2d 1135, 1140 ; Moore v. Roemer, 567 So.2d 75, 78 (La.1990). The party...
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