Unemployment Compensation – Labor Dispute Disqualification – Public Policy and the “Establishment”

Claimants brought suit for unemployment compensation allegedly due them for a period of temporary unemployment. Their employer manufactured spark plugs which were assembled at its Ohio plant using component parts made at its Michigan plant some 50 or 60 miles distant. The parts were transported daily by truck to the Ohio plant, and the Michigan plant was under the direct supervision of the Ohio plant. When a labor dispute occurred at the Michigan plant, lack of parts forced the lay-off of claimants at the Ohio plant. Upon termination of the labor dispute and a resumption of production the claimants resumed their employment. Claims for unemployment benefits under the Ohio statute, which denies benefits when the unemployment is due to a labor dispute at the “establishment,” were denied by the Administrator and Board of Review of Unemployment Compensation. The Court of Common Pleas affirmed and on appeal to the Court of Appeals of Ohio, held, affirmed, one judge dissenting. The Michigan and Ohio plants constitute one “establishment” within the meaning of the Ohio act. The two plants are functionally integrated, physically proximate, and there is general unity in their operation. Adamski v. State of Ohio, Bureau of Unemployment Compensation, (Ohio App. 1959) 161 N.E. (2d) 907.