Matter of Raven [Levine], 40 N.Y.2d 744 (1976): Unauthorized Signature as Employment Misconduct

40 N.Y.2d 744 (1976)

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An employee’s intentional and unauthorized signature on a document related to employment, even without intent to harm, constitutes misconduct that can disqualify them from receiving unemployment benefits.

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Summary

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Raven, a credit and collection clerk, was injured in an automobile accident and completed an insurance form, signing her manager’s name without authorization. The Unemployment Insurance Appeal Board disqualified her from receiving benefits, finding she lost her job due to misconduct. The New York Court of Appeals affirmed, holding that the unauthorized signature on a document related to employment constitutes misconduct, regardless of intent to harm or actual harm. The court emphasized that such conduct demonstrates a willful disregard of the standards of behavior employers expect from employees and bears on her fitness for her role.

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Facts

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Claimant Raven, a credit and collection clerk for a department store, sustained personal injuries in an automobile accident.r
Raven received a wage information request form from her insurance company.r
She completed the form and signed her manager’s name to it without authorization.r

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Procedural History

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The Unemployment Insurance Appeal Board disqualified Raven from receiving unemployment benefits.r
Raven appealed the Board’s decision.r
The Appellate Division affirmed the Board’s decision.r
The New York Court of Appeals affirmed the Appellate Division’s order.r

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Issue(s)

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Whether an employee’s intentional and unauthorized signing of an employer’s name on a document related to employment constitutes misconduct sufficient to disqualify the employee from receiving unemployment benefits.r

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Holding

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Yes, because the intentional and unauthorized subscription by an employee of an instrument in respect to the employment relation by use of an employer’s name, even though accomplished without intent to harm and not resulting in actual harm, constitutes misconduct within subdivision 3 of section 593 of the Labor Law. The Board was entitled to so conclude.r

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Court’s Reasoning

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The court reasoned that the Unemployment Insurance Appeal Board had the right to disqualify Raven from receiving benefits because she lost her employment through misconduct.r
The court stated that the