Temple University v. Unemployment Compensation Board of Review

In Temple University v. Unemployment Compensation Board of Review, 565 Pa. 178, 772 A.2d 416 (2001),the Court held that an employee's erroneous belief that she has a legal entitlement to property of an employer does not excuse an employee's violation of an employer's rules. Temple involved a case in which a hospital employee received pay for hours he did not work. The employee's supervisor had told the employee that he should be rewarded for good work performance and that he should add hours to his timesheets in order to receive additional pay. The Court reiterated the principle that "there can be no good cause for stealing from an employer" that would excuse such willful misconduct. 565 Pa. at 183, 772 A.2d at 418. In Temple, the particular policy the Court concluded the employee had violated stated that "the stealing or deliberate destruction of University property or the property other employees, patients, clients, students or visitors would result in termination." 565 Pa. at 181, 772 A.2d at 417. Thus, unlike Gibson, the particular employer rule in Temple simply prohibited stealing. In Temple, the Court resolved the issue by first considering whether that claimant lacked "legal entitlement" to the pay.