Interpreting a California statute enacted to comply with federal legislation, the Supreme Court in United Educators of San Francisco v. California Unemployment Insurance Appeals Board today broadens the opportunity for substitute teachers and other public school employees to collect unemployment insurance during the summer.
The court’s unanimous opinion by Justice Goodwin Liu holds that the statute — barring school employees from collecting benefits during “the period between two successive academic years or terms” if the employees worked during “the first of the academic years or terms” and received “reasonable assurance” of work during “the second of the academic years or terms” — does not apply in the summer if there is a summer session that constitutes an “academic term.” The court also concludes that “a summer session is an ‘academic term’ . . . if the session, on the whole, resembles the institution’s other academic terms based on objective criteria such as enrollment, staffing, budget, and the instructional program offered.”
The opinion has something for you issue preclusion mavens, too. (See here.) Relying on the “public-interest exception” to normal issue preclusion principles, the court rejects the binding effect of a 2005 superior court judgment because the resolution of the statutory construction issue “implicates the expenditure of public funds and will affect districts and school employees throughout California.”
The court reverses the First District, Division One, Court of Appeal. It also disapproves a 2013 precedent benefit decision by the California Unemployment Insurance Appeals Board.