1

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

 

MAURICE & JANE SUGAR LAW 

CENTER FOR ECONOMIC & 

SOCIAL JUSTICE, 

INTERNATIONAL UNION, UNITED 

AUTOMOBILE, AEROSPACE AND 

AGRICULTURAL IMPLEMENT 

WORKERS OF AMERICA (UAW), 

et al

 Plaintiffs, 

 

v.

STEVE ARWOOD and SHARON 

MOFFETT-MASSEY, in their official 

capacities 

 Defendants. 

Case No. 2:15-cv-11449 

Hon. Robert H. Cleland 

STIPULATED ORDER 

OF DISMISSAL 

________________________________________________________________ 

David M. Blanchard (P67190) 

Daniel Tai (P76798) 

BLANCHARD & WALKER, PLLC 

Attorneys for Plaintiffs 

221 N. Main Street, Ste. 300 

Ann Arbor, MI 48104 

Ava Barbour (P70881) 

Edward A. Macey (P72939) 

Associate General Counsel 

International Union, UAW 

Attorneys for UAW only 

8000 East Jefferson Avenue 

Detroit, MI 48214 

Kimberly K. Pendrick (P60348) 

Peter T. Kotula (P41629) 

Shannon W. Husband (P60352) 

Assistant Attorney General 

Attorney for Defendants 

Labor Division 

3030 W. Grand Blvd., Ste. 9-600 

Detroit, MI 48202 

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Page 2

STIPULATED ORDER OF DISMISSAL 

By consent and stipulation of the parties it is HEREBY ORDERED that: 

1. This matter is dismissed on the terms of the attached Settlement 

Agreement; and, 

2. Collection activity stayed under the stipulated Preliminary Injunction 

Order will continue: all collection activity against claimants who have 

been subject to fraud (re)determinations (and associated underlying 

eligibility or disqualification (re)determinations) issued by the 

Agency beginning October 1, 2013, to August 7, 2015, is stayed, 

unless and until individually reviewed by agency staff and affirmed 

with new notice to claimant; and, 

3. The Court shall retain jurisdiction of this matter pursuant to the terms 

of the Settlement Agreement and for the purpose of enforcing the 

terms of this Order and the Settlement Agreement; and, 

4. Plaintiffs shall be entitled to reimbursement of reasonable fees and 

costs incurred in the prosecution of this matter as agreed by the 

parties. 

IT IS SO ORDERED 

Dated: February 2, 2017 s/Robert H. Cleland 

 ROBERT H. CLELAND 

 UNITED STATES DISTRICT JUDGE

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STIPULATION 

 The parties, by and through their respective attorneys, stipulate to the entry 

of this order. 

Respectfully submitted, 

Date: January 31, 2017 

/s/ David M. Blanchard 

David M. Blanchard (P67190) 

Daniel C. Tai (P76798) 

BLANCHARD & WALKER, PLLC 

Attorneys for Plaintiffs 

221 N. Main Street, Ste. 300 

Ann Arbor, MI 48104 

Date: January 31, 2017 

/s/ Edward A. Macey 

Ava Barbour (P70881) 

Edward A. Macey (P72939) 

Associate General Counsel 

International Union, UAW 

Attorneys for UAW only 

8000 East Jefferson Avenue 

Detroit, MI 48214 

/s/ Kimberly K. Pendrick 

Kimberly K. Pendrick (P60348) 

Peter T. Kotula (P41629) 

Shannon W. Husband (P60352) 

Assistant Attorney General 

Attorney for Defendants 

Labor Division 

3030 W. Grand Blvd., Ste. 9-600 

Detroit, MI 48202 

Date: January 31, 2017 

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Page 1

Settlement Agreement 

THIS SETTLEMENT AGREEMENT (hereinafter referred to as 

“Agreement”), is made and entered into this 31 day of January, 2017, by and 

between International Union, United Automobile, Aerospace and Agricultural 

Implement Workers of America (UAW); and Maurice & Jane Sugar Law Center 

for Economic & Social Justice, and individual claimants Jennifer Zynda; Amanda 

Balma; Kevin Grifka; Jordan Miller; Brian Saylor; Nancy Wessinger; and Michelle 

Witt (hereinafter referred to as “Plaintiffs”) and the Talent Investment 

Agency/Unemployment Insurance Agency, Steve Arwood and Sharon MoffettMassey (hereinafter referred to as “Defendants”). 

WHEREAS, Plaintiffs filed a civil action in this Court on April 21, 2015, 

originally titled Zynda et al. v. Zimmer et al., 15- CV-11449 (the “Litigation” or 

“Action”). 

WHEREAS, the Agency has undertaken a review of all remaining 

Unemployment Insurance Agency (“UIA”) fraud determinations and 

redeterminations (collectively referred to herein as “(re)determinations”) and 

associated eligibility (re)determinations issued from October 1, 2013, to August 7, 

2015 that have not yet had a hearing before the Michigan Administrative Hearing 

System, which will include issuance of (re)determinations on reversals and 

notices of appeal rights on affirmations; and 

WHEREAS, the Agency has committed to make all reasonable efforts to 

complete the review within six months of the execution of this Agreement; and 

 WHEREAS, this Agreement sets forth the full and final terms by which 

Plaintiffs and Defendants settle and resolve all claims that have been raised in the 

Litigation. 

IT IS HEREBY AGREED that: 

1. The Litigation will be dismissed based upon entry of an Order of Dismissal 

incorporating the terms of this Settlement Agreement and on the mutual 

agreement of the parties and the obligations and affirmations contained 

herein; 

2. Defendants admit no wrongdoing or that any of the Talent Investment 

Agency/Unemployment Insurance Agency’s (Agency) policies or 

procedures violate any Federal or State Constitutional provisions or laws. 

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3. The Defendants hereby specifically affirm Agency compliance with the 

following policies and practices regarding identification of overpayments 

and/or imposition of penalties or, to the extent necessary, to adopt or revise 

policies. The Agency shall bring its policies and practices in compliance 

within 90 days of this Settlement Agreement. 

Section I. 

REVISED OR AFFIRMED UIA POLICIES AND PRACTICES 

4. The Agency will conduct an investigation consistent with prevailing U.S. 

Department of Labor requirements, including ETA Handbooks and 

Unemployment Insurance Program Letters as interpreted by the U.S. 

Department of Labor, before issuing a (re)determination that an 

overpayment has been made or intentional misrepresentation has occurred. 

In so doing, the Agency will take reasonable actions to ensure that 

investigators gather all relevant information, which may include supporting 

documents and statements from either the individual to whom the payment 

was made or others. In addition, claimants will be given an opportunity to be 

heard, timely notice of the interview or fact-finding questionnaire, and an 

opportunity to present evidence. 

5. When there is a factual conflict between the information received from an 

individual claimant and other information received by the Agency regarding 

overpayment or potential misrepresentation, Agency staff will make 

reasonable attempts (as defined by the U.S. Department of Labor) to contact 

the individual, inform him or her of the conflict, and allow an opportunity 

for rebuttal. The Agency will establish policies and procedures to determine 

that the conflicting information appears valid and relevant to its 

(re)determination prior to contacting the individual and requesting additional 

information. For purposes of paragraphs 1 or 2 of this section, the following 

practices shall satisfy the terms of the agreement: 

a. The Agency’s procedures require attempts to obtain information from 

the claimant, the employer, or third-parties regarding overpayment 

and misrepresentation issues; 

b. The Agency will issue (re)determinations of intentional 

misrepresentation based upon staff review of all evidence obtained 

during the investigation; 

c. The Agency will not make fraud (re)determinations solely based upon 

a lack of response by the claimant; 

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d. A manager will review all intentional misrepresentation 

(re)determinations to verify that they contain sufficient facts in 

support of the finding; 

e. The Agency will establish policies and procedures to determine 

whether conflicting information appears valid and relevant to its 

(re)determination prior to contacting the claimant and requesting 

additional information; and, 

f. Claimants that fail to respond to fact-finding will receive a 48-hour 

call before a fraud (re)determination is issued. 

6. All (re)determinations of misrepresentation or fraud will be issued only after 

the input and review by Agency staff, and after the claimant is informed of 

the conflicting information and provided an opportunity to respond. 

a. When reviewing a data conflict concerning reason(s) for separation, 

both the claimant and employer will receive fraud fact-finding 

questionnaires for fraud assessment purposes. Equal deference will be 

given to statements by the employer and the claimant absent further 

investigation by the Agency. This will apply to any new claims 90 

days after the effective date, which will be the date the Order of 

Dismissal and this Agreement are filed and entered by the Court. 

b. Claimants who fail to respond to fact-finding will receive a 48-hour 

call before a fraud (re)determination is issued. 

c. The Agency will not make fraud (re)determinations solely based on a 

lack of response by the claimant. 

d. All timely information submitted by a claimant will be considered 

prior to a (re)determination being issued. 

7. When an employer reports wages earned for an employee within a benefit 

quarter, the Agency will not assume that wages are compensation 

attributable to any specific benefit weeks throughout the quarter unless the 

employer or claimant designates the weeks for which it is attributing pay. If 

the employer so designates, the designation shall be subject to review by the 

Agency, and the claimant will be notified by phone call of the weeks 

designated and provided an opportunity to respond. 

8. Communications will be in plain language and using methods that ensure the 

communication is most likely to be successful for all populations, including 

individuals with limited English proficiency. 

9. Regardless of claimant’s election to receive electronic notices or “go green,” 

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after the end of the claimant’s benefit year, claimants accused of receiving 

overpayments or of intentional misrepresentation shall receive written notice 

by mail of the (re)determination at the last known address. Written notice 

will include: a) a summary statement of the material facts on which the 

(re)determination is based; b) the reason for allowing or denying benefits; 

and c) the penalties that will be collected or consequences associated with 

the (re)determination if it is not appealed and it becomes final. 

10. Written notice will also provide a statement of appeal rights that includes the 

claimant’s right to appeal, protest, or to request a redetermination; the period 

in which the appeal, protest, or request for redetermination must be filed; the 

manner in which it must be filed; and where the claimant can obtain 

additional information and assistance about filing an appeal, protest, or 

request for redetermination. 

11. All fraud (re)determinations and notices of restitution due will be reasonably 

designed to allow the claimant to understand the reasons for the 

(re)determination, potential penalties or other consequences of a fraud 

(re)determination, as well as his or her rights with respect to an appeal. The 

claimant shall be provided information about the appeal process including 

the right to have representation; to present testimony and other evidence 

relative to the appeal; to subpoena witnesses and records; and to be apprised 

of the penalties to be assessed if it is not appealed and a (re)determination 

becomes final, and of the consequences of failing to attend an appeal if one 

is requested. For purposes of this paragraph, inclusion of the following in 

fraud (re)determinations and notices of restitution due shall satisfy the terms 

of the agreement: 

a. A summary statement of the reason for denying benefits, including the 

facts on which the (re)determination is based (for (re)determinations 

only, but not notices of restitution due); 

b. The claimant’s right to protest or appeal a (re)determination; 

c. The period and manner in which the appeal, protest, or request for 

redetermination must be filed, and information regarding where the 

claimant can obtain additional information and assistance regarding 

filing an appeal, protest, or request for redetermination; 

d. The potential penalties or other consequences of a fraud 

(re)determination; 

e. The claimant’s ability to hire an attorney to represent them at any 

stage of the administrative process; 

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f. The claimant’s ability to use the advocacy program; 

g. That the claimant can have a hearing to present testimony and other 

evidence and to subpoena witnesses and records; and 

h. That failure to attend an administrative hearing may result in 

dismissal. 

Relative to any (re)determinations issued after implementation of any 

change of policy or procedure pursuant to this Agreement, the Agency will 

not initiate or continue overpayment recovery or imposition of penalties, 

whether by garnishment, bill collection, offset against current eligibility, or 

other means unless and until the above policies and procedures have been 

adhered to. 

12. The Agency will refer those who are denied advocacy through the Advocacy 

Program due to fraud to the State Bar referral service Legal Aid Section, 

which maintains an “unemployment” subsection. 

13. The Agency shall not initiate or continue recovery of an overpayment or 

penalty until a (re)determination of the overpayment becomes final after the 

claimant has had notice and reasonable opportunity to challenge the 

(re)determination and/or exhaust all appeals. 

14. During the pendency of a decision on any overpayment or misrepresentation 

(re)determination, the Agency will continue to make timely UC payments 

when due and shall not make any attempts to collect restitution while an 

appeal is pending, and shall not begin collection of restitution or penalties 

until or after 35 days from the date of a (re)determination. 

15. Good cause for a late protest will continue to include the situation wherein a 

claimant fails to receive a reasonable and timely notice, order, or decision, as 

set forth in Mich. Admin. Rule § 421.270. The Agency will make good 

cause determinations on a case-by-case basis based upon the information 

submitted. 

16. In cases where jurisdiction is returned to the Agency for reconsideration and 

redetermination under Mich. Admin. Rule § 421.270 the Agency will 

suspend collection activity of overpayment and/or penalties on that case(s), 

whether by garnishment, bill collection, offset against current eligibility, or 

otherwise, until a (re)determination on the case(s) has become final.

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Section II. 

CURRENT CLAIMANTS, GARNISHEES, AND OTHERS FOR WHOM THE 

STATE RETAINS REMUNERATION BASED ON CHALLENGED PRACTICES 

17. Review of Agency (re)determinations issued from October 1, 2013 to 

August 7, 2015, will be followed by new original (re)determinations by mail 

which shall be subject to the policies, procedures or practices outlined 

above, or “notices of appeal rights” which shall include explanation of the 

basis for upholding the original (re)determination and a copy of the original 

(re)determination. Relative to this review, funds garnished or otherwise 

collected shall be promptly returned within 30 days of a new 

(re)determination.1

 

18. For all claimants with open garnishment or other collection activity, all bills 

and garnishment notices shall provide a statement advising claimants that 

they may have: (1) a right to request reopening if they did not receive notice 

of the (re)determination within the original appeal deadline, and (2) the right 

to an individual hearing on the underlying issue(s). 

19. If the Agency rejects a request to reopen for good cause on the basis that the 

original (re)determination is more than a year old (MCL 421.32a(2) -- i.e. 

the “one-year letter” – currently UIA form 1077) it shall also include in the 

second paragraph of the main text of the “one year letter” information 

advising that, although the UIA is limited by a one year deadline: “However, 

if you file a protest or appeal of this denial, an Administrative Law Judge 

may reconsider the disputed issue after a year in some circumstances, and 

may grant your request if you did not receive notice of the original 

(re)determination or you establish good cause for late filing.” 

 

                                                            

1

 The parties understand that, in certain extenuating circumstances, it may be impossible to meet 

this deadline. Examples of extenuating circumstances include those cases where involvement of 

third parties -- such as employer garnishments or taxing authorities regarding interception -- 

limits or delays access to the funds, or cases in which return addresses must be verified or 

claimants located. In those cases the Agency shall endeavor to return collected funds as soon as 

practicable. 

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Section III. 

GENERAL SETTLEMENT TERMS 

20. Reporting. (1) For a period extending 24 months from the entry of this 

Settlement Agreement (the “reporting period”), the Agency will provide to 

Plaintiffs’ counsel a quarterly report, one month following the calendar 

quarter end, of the number of new fraud and nonfraud overpayment cases 

established based on new misrepresentation (re)determinations. (2) 

Quarterly, until completion of the review of cases subject to Section II of 

this Agreement, the Agency will provide information regarding the number 

of cases reviewed, the number of affirmations and reversals of fraud, the 

percentage of cases where refunds were issued on fraud penalties previously 

paid and the amounts thereof. 

21. Jurisdiction: The Federal District Court for the Eastern District of Michigan 

shall retain jurisdiction over this action. The Parties consent to continued 

jurisdiction of this Court over interpretation of the terms, enforcement, and 

compliance with this Settlement Agreement. 

22. Implementation: Within 90 days of the execution of this Agreement, the 

Defendant shall issue written directives to all applicable personnel within 

the Michigan Unemployment Insurance Agency clarifying its recovery 

procedures for overpayments of unemployment insurance benefits as 

provided in this Agreement. As soon thereafter as is practicable, but in no 

event more than 90 days of the execution of this Agreement, the Defendant 

shall issue revised manual sections for its policy and procedures manual(s) 

consistent with the terms of this Settlement Agreement. The Defendants will 

provide Plaintiffs’ counsel with a courtesy copy of the written directives 

issued pursuant to this Settlement Agreement at the time they are issued and 

an advance copy of the revised manual sections provided for under this 

paragraph no less than 15 days prior to their publication/distribution. 

23. Notice and opportunity to cure/Liaison. If Plaintiffs believe any Agency 

policy, practices, or actions are not in compliance with this Settlement 

Agreement, Plaintiffs shall give the Agency written notice of such alleged 

breach providing the opportunity to cure such breach for a period of thirty 

(30) business days after delivery of the notice. Within 10 days of notice, 

Defendants shall provide a response (written, by phone, or in person) of the 

actions proposed in response, if any. Any notice of breach shall be made to 

the following: 

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Talent Investment Agency/Unemployment Ins. Agency 

Attn: UIA Deputy Director 

Cadillac Place 

3024 West Grand Blvd., Ste. 12-350 

Detroit, Michigan 48202 

 The Agency will provide notice and copies of revised UIA forms2

 at least 60 

days (or as soon as practicable) prior to the proposed implementation. Any 

objection to the content of proposed UIA form revisions for compliance with 

this agreement must be raised within 30 days (or as soon as practicable) after 

receipt. Suggested and accepted changes will be made on a prospective 

basis. 

A Liaison for issues related to implementation of this Settlement Agreement 

and compliance shall be appointed within the Agency. The Agency may 

designate substitutions of the liaison by notice pursuant to the terms of this 

Agreement. The liaison is the UIA Deputy Director, and his or her designee, 

at a phone number and email to be provided by Defendants. 

24. Settlement Incorporated. Parties Agree to the Entry of this Settlement 

Agreement to be incorporated by reference in a Dismissal Order of the 

Litigation as final Resolution of the Litigation. If the Court rejects this 

Agreement in any material part, either party shall have the right to void this 

entire Agreement. 

25. Release. Except for the rights and obligations contained in this Agreement, 

Plaintiffs, including their officers, directors, managers, employees, agents, 

insurers, parent corporations, subsidiaries, affiliates (but not local chapters 

which the UAW has no authority to bind), predecessors, successors, assigns, 

hereby fully and forever release and discharge Defendants and its 

employees, attorneys, agents, representatives, insurers, predecessors, 

successors, and assign, from any and all manner of action and causes of 

action set forth in the pending litigation. 

 

                                                            

2

 UIA forms requiring notice pursuant to this provision are limited to claimant 

(re)determinations, restitution notices, questionnaires related to claimant benefits and/or fraud, 

monthly invoices to claimants, and the one-year letter. 

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26. Notice. If notice is required, it shall be made to the following: 

To UIA: 

Talent Investment Agency/Unemployment Ins. Agency 

Attn: UIA Deputy Director 

Cadillac Place 

3024 West Grand Blvd., Ste. 12-350 

Detroit, Michigan 48202 

To Plaintiffs: 

David Blanchard 

Blanchard & Walker PLLC 

221 N. Main St., Suite 300 

Ann Arbor, MI 48105 

The Parties may revise its notice persons at any time by written notice to 

each other. 

27. Severability. If any term or other provision of the Settlement Agreement 

and Dismissal Order is challenged by a Third Party, (“Third Party” is 

specifically defined to exclude the Parties herein, and any of their officers, 

directors, managers, members, employees, agents, insurers, parent 

corporations, subsidiaries, affiliates, predecessors, successors, and assigns), 

and ultimately held by a court of competent jurisdiction or the U.S. 

Department of Labor to be invalid, illegal, or incapable of being enforced, 

(a) either Party shall have the right to terminate the Agreement and 

recommence suit, notwithstanding any dismissal or initiate one or more new 

causes of action; or (b) upon written consent of all Parties, the full force and 

effect of all other terms and provisions of this Agreement shall be enforced, 

and there shall be substituted for the term or provision at issue a valid, legal, 

and enforceable provision that effects the original intent of the Parties as 

closely as possible. If either Party elects to recommence suit under this 

provision, (i) the Parties agree that any statutes of limitations are tolled from 

the filing date of the litigation to the date 90 days after any court finding that 

the provision of the Settlement Agreement and Dismissal Order is invalid, 

illegal, or incapable of being enforced, and (ii) neither Party will be 

prevented from pursuing any rights, claims or arguments. 

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28. Construction. Nothing contained in this Agreement shall be construed to 

require the commission of any act contrary to law, and whenever there is any 

conflict between any provision of this Agreement and any statute, law, 

ordinance, regulation, or U.S. Department of Labor direction, guidance, or 

UIPL, contrary to which the parties have no legal right to contract, then the 

latter shall prevail; but in such event, the provisions of this Agreement so 

affected shall be curtailed and limited only to the extent necessary to bring it 

within legal requirements and subject to the procedures of the preceding 

paragraph. 

29. Each of the Parties to this Agreement, acknowledge and represent that: 

a. Such Party has read this Agreement; 

b. Such Party clearly understands this Agreement and each of its terms; 

c. Such Party fully and unconditionally consents to the terms of this 

Agreement; 

d. Such Party has had the benefit and advice of legal and other counsel 

of such party’s own selection; 

e. Such Party has executed this Agreement fully, with knowledge, and 

without duress; 

f. Such Party is not relying on any other representations, either written 

or oral, express or implied, made by any other person or entity; and 

g. The consideration received by such Party has been actual and 

adequate. 

30. Authority. The parties and the individuals signing this Agreement represent 

and warrant that the individuals signing this Agreement are duly authorized 

and empowered to act on behalf of and to sign for the Party for whom they 

have signed respectively, and this Agreement has been duly and validly 

executed by them, and that this Agreement constitutes valid and binding 

obligations of the Parties. 

31. This Agreement does not prevent the Agency from making any necessary 

revisions to its policies and procedures required to ensure compliance with 

state and federal unemployment requirements, including U.S. Department of 

Labor direction, guidance or UIPL. In the event that changes in law require 

modification of this Settlement Agreement, the parties agree to provide 

notice at least 30 days in advance of the implementation of any new policy 

or practice required that would violate the terms of the Stipulated Agreement 

and shall, subject to the procedure for notice and cure, stipulate to 

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modification of the Settlement Agreement to the degree necessary to bring it 

into compliance. 

32. This Agreement contains the entire Agreement between the parties. Any 

modification of this Agreement must be made in writing and signed by the 

parties. 

33. This Agreement may be executed in counterparts by any of the signatories 

hereto, including by facsimile transmission, and as executed shall constitute 

one agreement. Facsimile or electronic copies of signatures shall be treated 

as originals for all purposes.

/s/ David M. Blanchard 

David M. Blanchard (P67190) 

BLANCHARD & WALKER, PLLC 

On behalf of all Plaintiffs 

Date: January 31, 2017

/s/ Edward A. Macey 

Edward A. Macey (P72939) 

Associate General Counsel 

International Union, UAW 

On behalf of Plaintiff UAW 

Date: January 31, 2017

/s/ Anthony D. Paris 

Anthony D. Paris (P71525) 

Lead Attorney 

Sugar Law Center 

On behalf of Plaintiff SLC 

Date: January 31, 2017

/s/ Wanda Stokes 

Wanda Stokes 

Director 

Talent Investment Agency 

On behalf of: 

Talent Investment Agency (TIA); 

Unemployment Insurance Agency 

(UIA); and the Officers sued in 

their official capacity. 

Date: January 31, 2017

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