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DAVID R. GARRETT VS. BOARD OF REVIEW (BOARD OF REVIEW, DEPARTMENT OF LABOR)

NJSUPERCTAPPDIVAugust 21, 2018No. A-0091-17T4
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Case Details

Status — whether other courts must follow this ruling
Unpublished
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Outcome

The Board of Review's decision disqualifying Garrett from unemployment benefits was affirmed. Garrett voluntarily left his job without good cause attributable to work when he declined a lateral transfer offer with the same pay and hours.

What This Ruling Means

**Unemployment Benefits Denied for Worker Who Refused Job Transfer** David Garrett worked for the Township of Mount Laurel and was offered a lateral transfer to a different position with the same pay and working hours. Garrett declined the transfer and left his job instead. He then applied for unemployment benefits, but the state's Board of Review denied his claim. Garrett appealed this decision to the court. The New Jersey appeals court sided with the Board of Review and upheld the denial of unemployment benefits. The court ruled that Garrett voluntarily quit his job without good cause related to his work situation. Since his employer had offered him a comparable position with identical pay and hours, the court determined he had no valid work-related reason to refuse the transfer and leave. **What this means for workers:** If your employer offers you a transfer to a similar job with the same pay and schedule, refusing it and quitting may disqualify you from receiving unemployment benefits. To qualify for benefits after voluntarily leaving a job, you generally need to show you had good cause related to your work situation, such as unsafe conditions, harassment, or significant changes to your job duties or compensation.

This summary was generated to explain the ruling in plain English and is not legal advice.

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