by Ryan Olson
Recently, the Minnesota Court of Appeals affirmed an unemployment law judge’s (ULJ) decision that an employee did not have good cause to quit her job because her reasons for resigning included an inability to perform her job duties and inadequate on-the-job training.
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Clerk Cannot Account for Her Work
“Dolores” was hired as an accounting clerk by Donaldson Company, Inc., in August 2015. Before she started work, the company told her that she would be trained by a contract employee, but she received most of her training from manuals and had limited one-on-one training. Dolores and her supervisor met on multiple occasions, and she had opportunities to ask about the company’s processes.
Despite receiving training opportunities, Dolores struggled to perform her initial responsibilities. Nevertheless, Donaldson continued to assign her additional duties within the scope of her employment. Dolores thought she had a “strained” relationship with her supervisor and suggested the issue was caused by her supervisor thinking she was learning her job duties too slowly.
Did She Quit?
Less than 2 months into her employment, Dolores met with her supervisor. The supervisor critiqued her performance but did not mention terminating her because of it. Rather, the supervisor asked her what the “next step” should be. Dolores said, “I think I should be done.”
Dolores ceased working for Donaldson 2 days after the meeting with her supervisor. After she stopped working for the company, she applied for unemployment benefits.
Dolores Quit Her Employment by Deciding to End It
Under Minnesota law, an employee who quits her job is ineligible for unemployment benefits unless her resignation is covered by an exception. If the decision to end the employment relationship was made by the employee, she quit.
The ULJ and the appellate court found that Dolores quit her job. Both Dolores and Donaldson stated she could have continued to work for the company if she had wanted to. Since she chose to end her employment, she quit.
Quitting for Lack of Training Isn’t Good Cause
Even though Dolores quit her job, she argued that the “good reason” exception entitled her to unemployment benefits. An employee who quits for a good reason caused by her employer may obtain unemployment benefits.
The reason must (1) be “directly related to the employment” and attributable to the employer (2) be “adverse to the worker,” and (3) “compel an average, reasonable worker to quit and become unemployed rather than remaining in the employment.”
The ULJ and appellate court rejected Dolores’ argument that her difficulties in doing her job because of inadequate training were good reason to quit. The court found that an average, reasonable worker would not choose to become unemployed rather than continuing her employment because she received less training than she wanted.
Additionally, the ULJ and appellate court rejected Dolores’ argument that Donaldson continuing to give her additional job duties when they fell within the scope of her employment provided her good reason to quit.
In particular, she did not mention she wanted additional training during the meeting in which she quit her employment. Those facts led the court to affirm the ULJ’s decision that she quit without good cause. Davies v. Donaldson Co., No. A16-0336, 2016 Minn. App. Unpub. LEXIS 985 (Minn. Ct. App., Nov. 7, 2016).
Takeaway
Even though Dolores did not have good cause to quit her employment, an employee can be eligible for unemployment benefits if her employer alters the expectations of her performance in such a way that she acquires good reason to quit.
For example, an employee whose hours are doubled and is given unreasonable demands that no one could be expected to meet may be eligible for benefits. Employers must take care to inform employees of their reasonable expectations and encourage open communication to avoid disputes.
Ryan Olson, an editor of Minnesota Employment Law Letter, can be reached at rolson@felhaber.com.