The Minnesota Court of Appeals recently heard a claim regarding an employee’s request for unemployment benefits. The employee quit his job, but offered conflicting reasons as to why he quit. Is the employee eligible for unemployment?
Meeting Leaves Employee Feeling Insulted
“Nelson” was employed as a lab assistant in the automotive department at Lake Superior College for 5 years. One day, the dean’s secretary scheduled a meeting between Nelson and the bookstore manager to discuss the “friction” between their departments. Nelson had simple instructions: Do not talk about the meeting to anyone, especially a particular coworker.
Nelson disregarded those simple instructions and brought the coworker to the meeting. The secretary informed the coworker that he had “no business being at the meeting,” and the coworker left. Nelson and the bookstore manager then started to argue. After the bookstore manager “raised her voice” and expressed her belief that Nelson got “into everything” and didn’t respect a student employee at the bookstore, Nelson left the meeting.
The following day, the bookstore manager e-mailed Nelson and other employees in the automotive department to inform them that she was going to limit the student employee’s responsibilities when he was working with the automotive department. Despite having no evidence, Nelson believed the bookstore manager told the student employee about their meeting.
A day later, Nelson informed the college’s security director about the meeting. He claimed that “he had never felt so insulted in his life” and he felt unsafe around the student employee. Although he had never been threatened by the student employee, he said he felt unsafe because the employee suffers from posttraumatic stress disorder.
The next week, Nelson quit his job, informing the college in his resignation letter that he quit because of mistreatment by the bookstore manager. A day later, he filed a formal complaint with HR “claiming that the bookstore manager had violated workplace policies and had shared confidential information with the student worker.” The complaint was investigated and found to be unsubstantiated.
ULJ Throws Monkey Wrench into Employee’s Claim
Nelson filed for unemployment benefits. The Minnesota Department of Employment and Economic Development (DEED) found that he was eligible for benefits because he quit for a good reason caused by his employer. The college appealed, and a unemployment law judge (ULJ) reversed DEED’s decision. Nelson appealed the ULJ’s determination that he wasn’t eligible for unemployment benefits.
Under Minnesota law, an employee who quits his job is typically ineligible for unemployment benefits. But if the employee quits for a “good reason caused by the employer,” he may be eligible for benefits if certain requirements are met. Specifically, the employee must demonstrate that:
- His reason for quitting was directly related to his employment and his employer was responsible;
- The circumstances that led him to quit were adverse to him.
- An average reasonable worker would quit rather than continue being employed.
In addition, the employee must complain to his employer and allow the employer a “reasonable opportunity to correct” the adverse conditions.
Unemployment Claim Runs Out of Gas
Ultimately, Nelson’s reason for quitting his job wasn’t enough to satisfy the “good reason caused by the employer” standard. He said he quit because of the bookstore manager’s conduct during their meeting, not because he felt unsafe around the student employee.
The Minnesota Court of Appeals agreed with the ULJ that “the manager’s conduct [in] one instance” wouldn’t “compel an average, reasonable worker to quit,” especially since Nelson had almost no contact with her otherwise.
The court also found that Nelson failed to give the college sufficient notice and a reasonable opportunity to correct the adverse conditions. He didn’t inform the college about his meeting with the bookstore manager before he quit; he only told the security director about it.
He also failed to give the college a reasonable opportunity to fix the situation because he submitted his resignation letter a mere 5 days after he spoke with the security director. There was no evidence that he ever followed up with the security director or anyone else at the college about his concerns. Wrazidlo v. Lake Superior Coll., 2017 Minn. App. Unpub. LEXIS 848 (Minn. Ct. App., Sept. 25, 2017).
What We Learn from This
In this case, one bad meeting wasn’t enough to force a reasonable employee to quit, but it’s certainly possible that in more extreme circumstances, a court could find a single meeting created an adverse employment condition caused by the employer. You should continue to train managers and others in leadership positions on how to maintain professionalism and engage in conflict resolution when they communicate with subordinates and coworkers.
Serena O’Neil, a contributor of Minnesota Employment Law Letter, can be reached at soneil@felhaber.com.