Utley v. Board of Review, Department of Labor

Worker Wins Unemployment Benefits After Employer Refuses Transportation Accommodation

This case involved a worker named Utley who resigned from Myron Manufacturing Corporation after the company changed his work schedule and refused to help him get to work. Utley had transportation challenges and asked his employer to either accommodate his schedule or allow him to use vacation time when he couldn't get to work. The company denied both requests, leaving Utley unable to reliably get to his job. He resigned and applied for unemployment benefits, but the state initially denied his claim.

The New Jersey Supreme Court ruled in Utley's favor, reversing the state's decision to deny unemployment benefits. The court found that Utley had "good cause" to quit because his employer's actions made it impossible for him to continue working. The court determined this was "constructive discharge" - essentially forcing someone to quit by making working conditions unreasonable.

This decision matters for workers because it shows that employees may be eligible for unemployment benefits even when they quit, if their employer creates impossible working conditions. Workers who resign due to their employer's failure to provide reasonable accommodations or inflexibility with scheduling may still qualify for unemployment compensation.