About 2 million Americans quit their job every month, at least some of those being here in our mountain home. The Utah Court of Appeals recently clarified and confirmed that an employee who unreasonably quits her job without good cause is ineligible from receiving unemployment benefits. Doxon v. Department of Workforce Services
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Sara Doxon had been working her job for 16 years. She loved her job. But then, about a year before her resignation, Sara began to consider quitting after her sister left Utah and moved to California. Sara wanted to be with her sister. As the thought of leaving became more serious, she began looking for another job in California. Sadly, her search was unsuccessful, and when the day came, she ultimately decided to resign without having a new job in California. She moved anyway and applied for unemployment benefits. But those benefits were denied.
Her request was declined by the Department of Workforce Services. And then by an administrative law judge. And then by the Workforce Appeals Board. And then, ultimately, by the Utah Court of Appeals which affirmed the lower decisions. The Court of Appeals drew heavily from the Utah Administrative Code.
The Utah Administrative Code states that when an employee voluntarily quits, the burden of proving the reasonableness of her action falls on the employee because, unsurprisingly, she knows the most about her reasons for quitting.
In order to be eligible for benefits she must prove either 1) she had a good reason - or "good cause" - for quitting or 2) she didn't have a good reason for quitting but still should be able to receive benefits out of fairness - or "equity."
In order to prove good cause, the former employee must show that
● Continuing to work would have created a bad situation - or adverse effect - for her, and
● She had no control over the adverse effect.
An adverse effect is something that would cause harm - economic, mental, physical, or social - to an average person in her position. To prove she did not have control over the adverse effect she must prove she
● Could not have reasonably continued working while looking for a new job
● Did not have other alternatives, such as transferring, requesting a leave, etc., and
● Notified her employer of the adverse effect, giving the employer an opportunity to fix the situation.
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If the former employee fails to prove she had a good reason for quitting then she can still argue she should receive benefits out of fairness - or in other words, make an "equity and good conscience" plea.
If it would be unreasonably harsh to leave the former employee high and dry, then the employee may still be eligible for benefits if she
● Acted reasonably, or rather, if a reasonable person in her position would have done the same thing, and
● Continued looking for a job immediately after quitting and continued to do so.
If she meets these requirements then she will be eligible for benefits, if she doesn't then she won't.
In the case of Doxon, the Court of Appeals determined she did not meet these requirements. They found that she did not quit for good cause because she left voluntarily and could have continued working while looking for a new job. Being away from her sister was just not a significant enough adverse effect to be considered good cause.
The Court also found she did not deserve benefits out of fairness. Her decision to quit her job was not reasonable in a legal sense.
They also noted that despite her insistence, the fact she had diligently searched for a new job was not the issue and did not affect the outcome.
The clear takeaway from the case of Doxon is that employers should be careful to not create a situation that gives an employee a reason to quit, and that employers may want to challenge claims filed by workers whom they believe quit unreasonably and without good cause. If you have more questions, find out more about employment law and consider speaking with an experienced legal professional.