Jenkins v. Hayes, IP 80-49-C.

• Decision Date: 20 April 1983
• Docket Number: No. IP 80-49-C.,IP 80-49-C.
• Citation: 560 F. Supp. 918
• Parties: Luella JENKINS v. Holton HAYES, et al.
• Court: U.S. District Court — Southern District of Indiana

560 F. Supp. 918

Luella JENKINS v. Holton HAYES, et al.

No. IP 80-49-C.

United States District Court, S.D. Indiana, Indianapolis Division.

April 20, 1983.

Legal Services Organization, Indianapolis, Ind., for plaintiff.

Deputy Atty. Gen., Gerald Coraz, Indianapolis, Ind., for defendants.

ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT

STECKLER, District Judge.

This matter comes before the Court on the parties' cross-motions for summary judgment. Fed.R.Civ.P. 56.

The facts giving rise to this lawsuit are relatively simple and undisputed. Plaintiff was an employee of the Indianapolis Public Schools under the CETA program. She worked as a library aide at Public School 59. She also was employed by the City of Indianapolis as a crossing guard at School 59 during half-hour periods before school, at noon, and after school. In August 1979 plaintiff was laid off from the library aide position when CETA funding expired. She applied and qualified for unemployment benefits as a result of the layoff. She would have received partial benefits because she had the crossing guard position. However, plaintiff quit the crossing guard job one week after the layoff because the travel would have consumed almost half her daily earnings and because the sporadic work times combined with travel time would have made it difficult for her to seek other full time employment. Under Ind. Code § 22-4-15-1, plaintiff's eligibility for partial unemployment benefits was terminated because she voluntarily quit the crossing guard job. Plaintiff alleges that Ind.Code § 22-4-15-1 violates the Equal Protection Clause of the Fourteenth Amendment in that it irrationally discriminates against and punishes persons who hold two or more jobs. She seeks to enjoin enforcement of the statute as against persons in her situation, a declaration that the statute is unconstitutional, and an award of benefits withheld from her.

Both parties seek summary judgment on the constitutionality question. Defendants also raise the defense of qualified immunity.

In evaluating a challenge under the Equal Protection Clause, the Court must determine (1) whether the challenged statute treats similarly situated persons differently, (2) if so, by what standard the resultant classification must be judged, and (3) whether or not the classification scheme meets the required standard.

There appears to be little disagreement between the parties that Ind.Code § 22-4-15-1 treats persons who qualify for partial benefits after involuntarily losing one job, and who subsequently quit a second job, differently from those who qualify for benefits after involuntarily losing their only job. The parties also agree that the appropriate standard by which the Court must evaluate the differentiation in treatment brought about by the statute is the rational relationship test. Schweiker v. Wilson, 450 U.S. 221, 101 S.Ct. 1074, 67 L.Ed.2d 186 (1981). In other words, the Court must determine whether terminating all unemployment benefits to a person who has held two or more jobs at one time and voluntarily quits one of the jobs after involuntarily losing the other is rationally related to legitimate state goals.

The Indiana Legislature stated the purpose of the Indiana Employment Security Act as follows:

"As a guide to the interpretation of this act XX-X-X-X-XX-X-XX-X, the public policy of this state is declared to be as follows: Economic insecurity due to unemployment is declared hereby to be a serious menace to the health, morale and welfare of the people of this state and to the maintenance of public order within this state. Protection against this great hazard of our economic life can be provided in some measure by the required and systematic accumulation of funds during periods of employment to provide benefits to the unemployed during periods of unemployment and by encouragement of desirable stable employment. The enactment of this measure to provide for payment of benefits to persons unemployed through no fault of their own, to encourage stabilization in employment, and to provide for a state employment service is, therefore, essential to public welfare; and the same is declared to be a proper exercise of the police powers of the state."

Ind.Code § 22-4-1-1.

Defendants assert that the purposes of Ind.Code § 22-4-15-1 are the same as the purposes of the Act as a whole quoted above, that is, provision of benefits to those unemployed through no fault of their own, and, promotion of employment stability. The defendants also discuss what the Court concludes are two sub-purposes which both serve to supply funds which can be paid out as benefits to qualifying individuals. These sub-purposes are (1) the avoidance of unnecessary tax rate increases to employers and (2)...