Early v. Employment Department

When determining unemployment benefits, employees are not required to have exhausted every single option after every issue in order to show that they left voluntarily but with good cause; the standard is whether a reasonable and prudent person with the same characteristics and qualities as the employee would have considered the situation so grave that he or she had no reasonable alternative but to voluntarily leave work.

Employee appeals the Employment Appeals Board’s (the Board) denial of unemployment benefits on the grounds that she had reasonable alternatives to quitting and therefore voluntarily left employment without good cause. After Employee was hired, a co-worker was hired with whom Employee had great difficulty working. Employee took concerns to managers several times, but they went unresolved. The stress and anxiety caused by this relationship exacerbated Employee’s depression and caused her to become suicidal. After being put under her co-worker’s supervision, Employee decided she had to quit. The question was whether a reasonable and prudent person with the characteristics and qualities of someone with depression would have considered the situation so grave that she had no reasonable alternative but to voluntarily leave work. The board determined that Employee’s work situation was grave, but they concluded that there were reasonable alternatives to quitting work: seeking conflict resolution services through HR or requesting unpaid leave of absence. The Court held Employee did not need to demonstrate that for each issue she explored every possible solution. The Board’s options were not reasonable. Employee had already tried conflict resolution several times and there was no evidence that one more try would have succeeded, and taking a leave of absence would not have solved to issues with the co-worker. Reversed and remanded.