Employees who quit their jobs to care for a member of their immediate family generally are qualified to receive unemployment benefits in Minnesota. However, the Minnesota Court of Appeals recently heard a claim in which a former employee was denied unemployment benefits due to the fact that “fiancée” doesn’t fall within the statutory definition of “immediate family member.”
“Howard” was working for Launch Technical Workforce Solutions, LLC, when his fiancée suffered a serious injury. He requested 30 days off to care for her and drive her to Texas to be closer to her family. Launch denied the 30-day leave but did allow him to take a little more than a week off.
Unfortunately, car trouble delayed the couple’s trip, and Howard’s fiancée took a turn for the worse. As a result, he notified Launch that he was quitting his job to remain with her.
Howard subsequently filed an application for unemployment benefits with the Minnesota Department of Employment and Economic Development (DEED). DEED denied his claim, leading Howard to appeal the denial of benefits to the Minnesota Court of Appeals.
Minnesota Court of Appeals’ decision
Employees typically are denied unemployment benefits when they voluntarily terminate their employment. Howard contended that his actions met two exceptions to ineligibility for benefits: (1) quitting for a good reason caused by his employer and (2) quitting to provide necessary care for an immediate family member.
The court was unpersuaded by Howard’s first argument. He alleged that he wouldn’t have quit his job had Launch given him 30 days off as he initially requested. However, the court noted that he accepted Launch’s offer of less time off, and he couldn’t cite any requirement that obligated the company to give him the full 30 days off. Thus, the court concluded that granting him the shorter leave from work didn’t amount to “an adverse employer action . . . that would compel an average person to quit.”
The court then turned to Howard’s second argument—that he qualified for an exception because he quit his job to care for an “immediate family member.” The Minnesota unemployment insurance statute provides that an employee who resigns “to provide necessary care because of the illness, injury, or disability of an immediate family member” is eligible for unemployment benefits. That exception applies only if the employee notifies the employer and requests an accommodation, but no reasonable accommodation is forthcoming.
The statute specifically defines an “immediate family member” as “an individual’s spouse, parent, stepparent, grandparent, son or daughter, stepson or stepdaughter, or grandson or granddaughter.” Howard maintained that his fiancée qualified as his spouse and therefore fell within that definition. The court of appeals thought differently, noting that statutory wording must be interpreted in accordance with its common and approved usage.
“Spouse” describes a person’s husband or wife by lawful marriage. According to the court, “A fiancée does not fall under the definition of immediate family member because a fiancé is not a spouse.” As a result, Howard didn’t qualify for the exception, and his claim for benefits was denied.
Howard also attempted to argue that he and his fiancée were in a common-law marriage under Texas law because they had previously lived in that state. The court rejected that argument as well, noting Texas’ common-law marriage law requires evidence that a couple (1) agreed to be married and (2) represented to others that they were in fact married while they lived in Texas.
Howard couldn’t point to evidence of either, having referred to his fiancée as “his fiancée” throughout the proceedings. Simon v. Launch Tech. Workforce Solutions, LLC, 2017 Minn. App. Unpub. LEXIS 207, *1-2 (Minn. Ct. App., Mar. 6, 2017).
Words have specific meanings, and certain words are presumed to be used for precise reasons. The unemployment law contains a very detailed and exact list of relatives to whom the “care” exception applies, and the court had little appetite for adding to it.
James Sadkovich is a contributor to Minnesota Employment Law Letter.