## Facts

- Jason Sauerland worked as a juvenile-detention officer at a juvenile detention facility.
- Sauerland’s duties included making “rounds,” meaning visual checks of each room under his supervision every 10 minutes.
- He was required to document each round by recording it in a logbook.
- The rounds and logging requirements were explained during employee orientation and set out in an employee handbook Sauerland received.
- Sauerland knew that falsifying logbook entries was grounds for termination.
- On September 28, 2004, Sauerland recorded that he completed rounds at 3:00 a.m., 3:30 a.m., 3:40 a.m., and 3:50 a.m.
- Facility videotape showed Sauerland did not perform rounds at most of the logged times and that at least two logged rounds were not performed.
- Sauerland was terminated for falsifying the logbook.
- Sauerland applied for unemployment-compensation benefits and was disqualified based on misconduct connected with work.
- The Florida Unemployment Appeals Commission affirmed the disqualification, and Sauerland appealed to the First District Court of Appeal.

## Issues

1. Whether Sauerland’s knowing falsification of required security-round logbook entries constitutes “misconduct connected with work” that disqualifies him from unemployment-compensation benefits under Florida law.

## Decision

- The First District Court of Appeal affirmed the Florida Unemployment Appeals Commission’s order disqualifying Sauerland from benefits.
- The court treated the false log entries as intentional falsification rather than mistake.
- The Commission’s findings were supported by competent, substantial evidence, including the videotape evidence contradicting the logbook.
- Because the misconduct finding was supported and the conduct was connected with Sauerland’s job duties, the disqualification from unemployment benefits was upheld.

## Legal Principles

- For Florida unemployment-compensation purposes, “misconduct” includes willful or wanton disregard of an employer’s interests and deliberate violation of standards of behavior the employer may reasonably expect.
- Knowingly falsifying employer records related to assigned duties may constitute misconduct connected with work.
- Misconduct can be found even without proof of actual harm where the conduct involves dishonesty tied to required job functions.
- On review of a Commission order, the appellate court defers to factual findings supported by competent, substantial evidence and addresses whether those facts satisfy the legal definition of misconduct.

## Conclusion

Sauerland’s unemployment-compensation disqualification was affirmed because the record supported a finding that he knowingly falsified logbook entries for required 10-minute security rounds, which amounted to misconduct connected with work under Florida law.


Sauerland v. Florida Unemployment Appeals Commission, 923 So.2d 1240 (2006)