In the case of Meinerding v. Coldwater Exempted Village School Dist. Bd. of Edn., 2019-Ohio-3611, an Ohio appellate court held that a teacher who chose to resign prior to the initiation of termination proceedings quit “without just cause” and was, therefore, not eligible for unemployment compensation benefits.
In this case, a teacher was placed on administrative leave as a result of a fight between two students under her supervision. After an investigation, the superintendent subsequently recommended termination of the teacher’s contract to the school board. Prior to the school board taking action on the superintendent’s recommendation, the teacher agreed to resign in exchange for an acceptance of the resignation without public comment.
The teacher subsequently filed for unemployment compensation benefits arguing that termination was imminent. The Unemployment Compensation Review Commission (“UCRC”) disagreed and ruled against granting unemployment compensation benefits as the teacher’s discharge was not inevitable based, in part, on evidence in the record regarding the timing of the resignation, the negotiation with the school district for favorable resignation terms, and the teacher’s decision not to challenge the basis for the school district’s termination recommendation. As a result, the UCRC found that these factual considerations negated the teacher’s assertion that the decision to quit was involuntary because the teacher faced an alleged ultimatum and had no choice but to resign.
The Ohio appellate court upheld the decision of the UCRC because – in this case – the teacher failed to prove that the teacher quit with just cause. In support of its decision, the appellate court explained that:
An analysis of just cause must also consider the policy behind the Unemployment Compensation Act, which was intended to provide financial assistance to individuals who become unemployed through no fault of their own. Accordingly, “fault” on an employee’s part is an essential component of a just cause termination. The determination of whether an unemployment compensation claimant had just cause to quit his or her job depends on the unique factual considerations of a particular case and is, therefore, primarily an issue for the trier of fact. Meinerding, at ¶21 (omitting citations).
It is important to note that the outcome of this case may have been much different if these facts were different. So, whether a resignation will preclude unemployment benefits is a case-by-case analysis.
To read this case, click here.
Authors: Matthew John Markling and the McGown & Markling Team.
Note: This blog entry does not constitute – nor does it contain – legal advice. Legal jurisprudence is always changing like the Midwestern weather. As a result, this single blog entry cannot substitute for consultation with a McGown & Markling attorney. If legal advice is needed with respect to a specific factual situation, please feel free to contact a McGown & Markling attorney.