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Voluntary Quit - Section 8-1001 - Maryland Unemployment Decisions Digest - Appeals

Voluntary Quit - Section 8-1001 continued

B. Conditions of Employment

1. General Dissatisfaction with the Job
The claimant property manager resigned his employment after two years to seek employment in another field because he was no longer willing to cope with the hectic and demanding nature of his job. The claimant was well aware of these job conditions at the time of hire. The claimant has neither good cause nor valid circumstances for resigning. Gisriel v. Charles H. Steffey, Inc., 1085-BH-83.

The claimant police matron believed a secretary in the office was not performing a sufficient amount of work and, on reporting it, was told the matter would be taken care of. The claimant resigned after becoming dissatisfied that her complaints did not have a more obvious and dramatic effect. The claimant's frustration with what she considered to be another employee's failure to live up to the rules does not constitute good cause or a valid circumstance. Lyons v. Baltimore County Police Department, 16-BH-86.

The claimant's coworkers failed to act in a friendly manner towards her. However, the employer is not required to provide a working atmosphere in which coworkers are friendly toward the claimant. The claimant left without good cause or valid circumstances. Veney v. Greater S.E. Community Hospital, 409-BR-87.

The claimant voluntarily quit because she could not get along with a coworker. This coworker was a son of one of the owners. The employer was aware of the conflict and talked about it with the claimant and the other employee. The claimant stated that she could handle the situation. However, subsequently, the claimant resigned. The claimant quit without good cause or valid circumstances. There was insufficient evidence that the claimant was harassed or treated unfairly. McClain v. D and G Container, Inc., 187-BH-90.

The claimant misunderstood the position of secretary, which she took in good faith, which resulted in the claimant spending one-half of her time doing non-secretarial work. The claimant's leaving was for valid circumstances. Wingate v. American Trading and Production Corporation, 203-BR-87.

The claimant took a job, not understanding that her pre-existing medical condition made it impossible for her to perform her job duties. As soon as she realized that the job was medically unsuitable, she quit. Since the job was, in fact, medically unsuitable from the beginning, the quit was for good cause. Dean v. Eddie's Cleaners, Inc., 1114-BR-92.

The claimant was not provided with a suitable work place or the necessary equipment to do her job as a clerk typist, and she was not given assignments commensurate with her job classification, although she took steps to bring the problem to the attention of her superiors to no avail. The claimant left for good cause. Moore v. Department of the Army, 170-BH-89.

At the time of the claimant's hiring, he discussed with the employer the fact that he was unfamiliar with the type of fork lift used by the employer. Both parties agreed that the claimant would try to learn the job. The claimant received no training. After three weeks, the claimant found that he could not use that type of fork lift, despite making good faith efforts to learn, and he quit. The claimant had good cause for quitting the job. Smith v. Circuit City Stores, Inc., 1747-BR-93.

2. Hazardous Conditions
The claimant was required by his employer to violate state and federal health and safety regulations in performing his work (asbestos removal). The claimant walked off without notice because he had already complained and had no expectation that further complaints would lead to a better result. The claimant quit with good cause. Hughes v. All State Boilers, 256-BR-86.

The claimant truck driver resigned due to alleged safety problems with his vehicle. However, the employer had repaired every significant safety defect prior to the claimant's resignation. The claimant quit for neither good cause nor valid circumstances. Dalton v. Francis O. Day Company, Inc., 1025-SE-85.

The claimant did not prove that working with a person who has AIDS endangered her health, thus her leaving was without good cause or valid circumstances. Morris v. Maryland National Bank, 339-BH-87.

The claimant presented a medical certificate to indicate an allergic reaction to a chemical used at the employer's premises, and her doctor advised her to secure a new position where she would not repeatedly come in contact with chemicals and water. The claimant's leaving was for a good cause. Deale v. Simpson Land Company, 390-SE-89.

The claimant felt that paint was causing his medical problems but did not seek medical attention, never informed his employer of the problems, and did not ask for a transfer. This denied the employer any opportunity to check out the matter or make corrections. The claimant left work voluntarily without good cause or valid circumstances. Berry v. Tnemec Company, Inc., 509-BR-89.

The claimant quit for good cause where she had repeatedly complained to the employer that the employer's machine gave off fumes that were very irritating to the claimant's eyes and throat, but the employer failed to take any action to correct the problem. After the claimant resigned, she filed a complaint with MOSH, who notified the employer. Within ten days of this notification, the employer notified MOSH that it had corrected the problem. Hanna v. Clinton Dental Lab, Inc., 956-BH-90.

The claimant was hired with the understanding that she would be working in a nonsmoking office. Due to her sensitivity to smoke, she would not have accepted the job otherwise. However, the employer did not have a nonsmoking office. The claimant voluntarily quit for good cause. Mardis v. The Baltimore Sun, 211-BR-90. NOTE: This case was decided prior to the promulgation of COMAR 09.12.23, effective March 27, 1995, which prohibits smoking in an enclosed workplace.

The claimant conducted on-site repair of vending machines. He worked his territory with another worker, who was terminated and not replaced. Although the claimant was never robbed or beaten on the job, he was threatened by people while on the job, and he had seen armed men on the premises. One manager carried a gun, and a dead body had been found behind one of the buildings. The employer acknowledged that the claimant's territory was definitely dangerous, but he did not hire anyone to help the claimant, despite repeated requests. Although going into dangerous neighborhoods was part of the job, the claimant's requests that the employer rehire someone to help him was not unreasonable, given the dangerous nature of the area and the history of using two or more men to serve the area. The claimant quit without good cause, but with valid circumstances. Smith v. Macke Laundry, 1661-BR-92.

3. Threats, Assaults and Crime

a. By Employer
The fact that an employee does not immediately quit after being physically assaulted by her employer, when the assault in itself was a sufficient reason to establish good cause, does not mean that the reason she quit was not good cause. Lockhart v. Lyschik, 300-BH-92.

b. By Coworkers
The claimant had good cause to resign where she was threatened with serious bodily harm by a coworker, and the employer's higher management refused to transfer or terminate the offending coworker. The claimant took all reasonable steps to alleviate the problem prior to resigning. Hickerson v. McDonald's, 1245-BH-82.

4. Instability of Job or Business

a. Job
The claimant voluntarily quit for good cause where the employer was being taken over by the federal government and another bank due to financial problems and where the claimant's future there was uncertain. If the claimant had a job after the takeover, it would have been under different conditions and at reduced pay. The claimant's supervisor strongly advised her to seek other employment, and she did so. Himes v. Baltimore Federal Financial, 979-BH-90.

A claimant, who was informed that his job was coming to an end in two weeks, and that he would be laid off, quit before the two weeks were up and accepted an equivalent job elsewhere. The claimant's reason for leaving was connected with the total conditions of employment and constituted good cause. Gaillot v. Lane Construction Corporation, 481-BR-92.

The claimant discovered that she was definitely going to be fired, but that the employer was not going to tell her until she could be replaced. The claimant, who was a good worker, quit before she was fired. The claimant had good cause connected with the work to quit her job. Butler v. Circle Graphics, Inc., 852-BH-92.

Having been laid off from one office, the claimant commuted 27 miles to another office and found that she was unable to earn substantial commissions there. She was given a quota but was unable to fulfill that quota, despite her best efforts, and the employer's reminders of this had reached the point where he was hinting that she was about to be let go. These reasons taken together constitute a substantial cause for leaving the job, thus qualifying as valid circumstances under the law. Treadway v. Sovero Associates, Inc., 1582-BR-92.

b. Business
The claimant's reason for leaving was that the employer's contract would expire in a few weeks and the employer could not guarantee continued employment after that.This was a substantial cause connected with the conditions of employment, which is a valid circumstance. Warren v. Melwood Horticultural Training Center, Inc., 969-SE-93.

The claimant voluntarily quit because he was notified that the employer would close in four weeks and because his responsibilities and commissions were substantially decreased during the last year due to poor business conditions. These reasons are not good cause because the claimant quit while several weeks of work were still available, and the change in the claimant's responsibilities was due to economic conditions. However, the impending demise of the business and loss of commissions was a substantial cause. Therefore, the claimant voluntarily quit without good cause, but with valid circumstances. Bressler v. Maryland Metal Moulding Company, 122-BR-91.

The claimant had an offer of work with the person who was planning to buy the equipment from her current employer and start up a new operation. Rather than wait for her current employment to disappear, she moved to the new employer prior to being discharged. The fact that the current employer was selling its equipment and closing its operations was a substantial cause, connected with the conditions of employment, and therefore, was a valid circumstance. Woollard v. Peoples Service Drug Stores, Inc., 1740-BR-92.

The claimant became aware that the business was about to be sold and that the result would be his layoff. As a result, he attempted to start his own business. Since the claimant came up with his plan to become self-employed only after learning that his regular job was coming to an end and he would soon be left without work, the primary reason for the resignation was the impending layoff and not the desire to become self-employed. The claimant quit for valid circumstances. Diggs v. F.E. Vale, Inc., 373-BR-86.

Although the employer was in a degree of financial trouble, the claimant did not have any reasonable fear of an impending layoff. The claimant did not meet the burden of showing that she left for good cause or valid circumstances. Humbert v. The Martin Pollak Project, 736-BH-87.

5. Leaving to Accept a Better Job
Voluntarily quitting one's job to accept better employment cannot constitute good cause within the meaning of Section 8-1001 as a matter of law. Total Audio - Visual v. DLLR, 360 Md. 387, 395, 758 A.2d 124, 128 (2000)("[a] plain reading of Section 8-1001 makes clear that leaving employment for a better paying job does not constitute 'good cause'.") It may, however, constitute "valid circumstances" if it can be shown that the reasons for quitting meet the "necessitous or compelling" test of Section 8-1001(c)(ii). Section 8-1001(c)(i) is inapplicable as a matter of law in cases such as the one at bar. The Court of Appeals found, "[n]ot being directly related to, attributable to or connected with the employee's employment or the actions of that employing unit, offers of higher pay as an inducement to leave existing employment must fall, if at all into [Section 8-1001(c)(ii)]."

This is a stricter test than the "good cause" test. Plein v. DLLR, 369 Md. 421 (2002). Under this stricter test the Court of Appeals requires that more needs to be shown and that the precipitating event or cause "would reasonably [have] impel[led] the average able-bodied qualified worker to give up his or her employment." Total Audio - Visual, supra, quoting Board of Educ. of Montgomery County v. Payner, 303 Md. 22, 29, 491 A.2d 1186, 1189-90 (1985).

The Board's current interpretation of Total Audio - Visual, read in conjunction with the Plein decision, finds that voluntarily quitting one's job for purely economic reasons is neither "necessitous" nor "compelling" under Section 8-1001. To the extent that this interpretation is inconsistent with Gagne v. Potomac Talking Book Services, Inc., 374-BH-03, the Board overrules its prior precedent decision in Gaskins v. UPS, 1686-BR-00.

There must be a showing of something more connected with the conditions of the prior employment which motivated the claimant to quit his or her job to better employment to constitute a valid circumstance within the meaning of Section 8-1001. The Court of Appeals has stated, "Accepting more money and changing jobs is as much of a gamble and thus, as much of a personal matter as going in to business for oneself. In [the Court of Appeals'] view, it is unmistakably clear that Section 8-1001(a) was not designed to provide benefits when the precipitating cause for the voluntary leaving of employment was for higher pay or a better job. Instead, it was designed to prevent hardship to persons who lose their job "through no fault of their own." Plein v. DLLR, 369 Md. 421 (2002), quoting Total Audio - Visual.

In Plein, supra, the claimant was employed by Atlas Tile & Terrazo as a tile setter's helper at a job paying $9.00 per hour. He accepted employment with Home Depot, U.S.A. as a sales associate in the floor and wall department. The Home Depot job paid $12.00 per hour with the prospect of receiving, after a waiting period, a health insurance plan and stock purchase options and, after one year, two weeks vacation and sick leave. The claimant left his employment with Atlas and began working at Home Depot on August 14, 2000. On September 27, 2000, the claimant was laid off through no fault of his own. The Courts of Appeals found that the claimant was not entitled to unemployment benefits under the "necessitous or compelling" test of Section 8-1001 under its interpretation and under the authority of Total Audio - Visual, 360 Md. 387, 400-01, 758, A.2d 124, 131-32 (2000).

The Court explained in Plein, "In Total Audio-Visual, this Court, albeit, and perhaps significantly so, a sharply divided one, determined, and held that the General Assembly did not intend that a person who voluntarily terminates his or her otherwise satisfactory employment for other employment with better pay be eligible to receive unemployment benefits when laid off through no fault of his or her own by the subsequent employer."

6. Leaving Part-Time Work
NOTE: Section 8-1001(a)(2) was added to the statute October 1, 1995. It states that a claimant who is otherwise eligible for benefits from the loss of full-time employment may not be disqualified from the benefits attributable to the full-time employment because the claimant voluntarily quit a part-time employment, if the claimant quit the part-time employment before the loss of the full-time employment.

The claimant was laid off from Bethlehem Steel where he earned $10.00 per hour for a 40 to 48 hour work week. While unemployed, the claimant accepted part-time employment at the minimum wage. The claimant resigned his part-time employment when he was recalled by Bethlehem Steel. The claimant had good cause for leaving the part-time job. Ratliff v. Taco Bell, 2067-BR-83.

C. Personal Problems and Beliefs

1. In General

a. Necessitous or Compelling
The claimant's abandonment of her job was due to urgent and compelling personal circumstances. One of the claimant's grandchildren had died under suspicious circumstances, and she was concerned for her other two grandchildren. The claimant quit with valid circumstances. Greenway v. Katzenberg Brothers, Inc., 1027-BR-89.

The claimant, who worked almost every weekend, was continually put in the position of choosing between employment or maintaining visitation rights with her son. She quit her job in order to maintain visitation rights. The claimant voluntarily quit without good cause, but with valid circumstances. Sealock v. Turner Development Company, Inc., 928-BR-90.

The claimant quit her job due to compelling financial circumstances. After suddenly being left as the sole support of her children, the claimant made a serious effort to economically survive. However, she found herself simply unable to afford living in the area and left to move in with a relative who resided out of state. The claimant quit her job without good cause, but with valid circumstances. Durst v. W. Bell and Company, Inc., 598-BR-90.

b. No Reasonable Alternative
The claimant voluntarily quit in order to help his parents due to a family emergency. No one else could help the claimant's parents. The claimant had no reasonable alternative but to leave his job. The claimant voluntarily quit for valid circumstances. Pyles v. Jems Contracting, Inc., 997-BR-91.

The claimant was working in Japan when he was notified that his mother, who resided in New Jersey, was in a coma and could die at any time. The claimant quit his job and went to New Jersey to be with his mother. This was a personal reason of a compelling nature, that left him no reasonable alternative other than to leave his employment. Since the claimant did not leave because he was required to care for his mother, documentation of his mother's medical condition is not required. Lahood v. University of Maryland, Asian Division, 2096-BR-92.

No reasonable alternative to quitting existed where the employer listed a number of alternatives at the unemployment hearing, but where none had been actually offered to the claimant when she brought up her problem in the course of the employment. Therefore, the claimant quit for valid circumstances. Pearson v. Annapolis Life Care, Inc., 1013-BR-92.

2. Transportation
Every employee, at some point in her career, has transportation problems. Only when the problems are so severe as to be necessitous or compelling, and where it has been shown that there was no reasonable alternative other than to quit, do transportation problems amount to valid circumstances. Griffin v. Johns Hopkins Hospital, 1313-BR-93.

After the claimant did not show up for a ride to work, he was told that he would not be picked up anymore. The claimant did not show up for work after that. The claimant's leaving was without good cause or valid circumstances. Perry v. Fredco Construction Company, 399-BH-88.

The claimant lost his transportation through his own fault when his car was repossessed. Therefore, he had no valid circumstances for voluntarily quitting. Young v. Robert F. Thorne, Sr., 834-BR-88.

The claimant voluntarily quit because he had no transportation after his car broke down. The claimant made every attempt to get to the job but was unable to do so. The claimant tried to get a loan to repair his car but was unable to obtain one. The claimant voluntarily quit without good cause, but with valid circumstances. Avery v. Robert A. Kinsley, Inc., 240-BR-91.

The claimant voluntarily quit after only three days of car trouble. She failed to make an extensive investigation of transportation alternatives and failed to explain why the problem was intractable. The employer had not given the claimant a final warning. The claimant voluntarily quit without good cause or valid circumstances. Ellinger v. Howard County Government, 422-BR-91.

The claimant was hired to begin work at 7:00 a.m. at a location that was not accessible by public transportation at that hour. At first, the claimant rode with a coworker. Later, the employer let him use a company vehicle. The employer's withdrawal of its offer of the use of the vehicle, after the claimant worked one year in these circumstances, constitutes a valid circumstance. Appleman v. B and J Pool Contractor, Inc., 21-BR-93.

Although transportation to and from the job site is primarily the responsibility of the employee, the claimant's inability to obtain other transportation at an hour when public transportation is not available, constitutes valid circumstances for resignation. Johnson v. Direct Marketing Association, 1814-BR-82.

The claimant lost, through no fault of his own, his only transportation to a job located 50 miles from his home. The claimant accepted this job despite the distance to alleviate his previous unemployment. The claimant's resignation was not for good cause, but was for valid circumstances. Apson v. Kenster Tri-State and Company, 655-BH-83.

3. Distance from Work
The claimant voluntarily moved a distance of 37 miles from her place of employment and then resigned due to distance. No effort was made to resolve the transportation problems. The claimant's resignation was without good cause or valid circumstances. Ennis v. Ramada Hotel, 701-BH-84.

The claimant received threats on her life and for this reason moved 60 miles from her place of work. The claimant resigned due to distance. The reason for the claimant's resignation was personal in nature and does not constitute good cause. However, the claimant had a compelling personal reason for resigning, and valid circumstances were supported. Riggs v. Technitrol, Inc., 922-BR-85.

The claimant worked for a year on a job that was about 400 miles from his family. He could only see his family on weekends. He was also angry with the employer about a bonus which he mistakenly believed was due him. The claimant quit with valid circumstances since he worked extremely far from home and did make an effort to keep working even at the cost of his personal convenience. Ruckert v. Mr. Kool Service Company, Inc., 243-BH-87.

4. Health Problems

a. In General
The claimant had to breast feed her baby and would have had to work in an area of various chemical exposures which could be dangerous to breast feeding. The employer would not extend her leave. The claimant's leaving was for a necessitous and compelling reason and she had no reasonable alternative other than to leave. Her documentation and testimony was sufficient to find valid circumstances. Mills v. Martin Marietta Corporation, 353-BR-89.

The claimant worked 20 hours per week and the job required riding a bus to five different locations per week. This was quite stressful, and caused the claimant's diabetes to worsen. At times she felt shaky and was having problems seeing. The claimant had a necessitous and compelling reason for leaving her job and had no reasonable alternative but to do so. This constitutes valid circumstances. Macon v. Department of Health, 465-BH-89.

The claimant accepted employment knowing that he would be assigned to a trailer which was over 1,000 feet away from the nearest restroom. However, the claimant's stomach problems required that he be near a restroom at all times. When the claimant was unable to work with the restroom so far away, he quit without informing the employer of the problem. Good cause cannot be found where the employer was not informed of the claimant's health problem so that an accommodation might be made. However, valid circumstances are supported. Dunn v. Goodwill Industries, 286-BR-84.

The claimant was physically unable to perform a new assignment, due to a documented medical problem of which the employer was aware. The claimant explained this to the employer, but the employer insisted that the claimant perform the work or quit. The claimant's decision to quit rather than continue to risk his health is a voluntary quit for good cause. Leech v. Leonard W. Kearney, et al., 830-BH-93.

b. Evidentiary Requirements
The claimant voluntarily quit because he was experiencing severe stress and burnout on the job. The claimant produced medical documentation confirming this. The claimant's psychological condition was a substantial cause for quitting. The claimant voluntarily quit without good cause, but with valid circumstances. Friedman v. Maryland Treatment Center, Inc., 1340-BR-91.

The claimant quit without notice after he informed the employer that he was having back problems. Although the claimant produced medical documentation that he suffers from "low back syndrome," he had been working at his job up until his last day of work without any noticeable problems or complaints. The claimant's doctor's notes do not match the claimant's actions and statements prior to his last day of work. The Board found no significant medical injury. The claimant quit without good cause or valid circumstances. Shaffer v. McHenry, 838-BH-90.

There is no requirement under Section 8-1001(c)(2) that the medical document state that the claimant's physician specifically advised her to quit the employment. Miles v. Patriarch, Inc., 1982-BR-93.

The medical documentation required under Section 8-1001(c)(2) of the law need not state that the claimant is needed to assist the ill person. Whether the claimant's assistance was actually needed is an issue of fact which must be decided based on the totality of the evidence presented. Winchester v. Wareheim Air Brakes, Inc., 77-BR-93.

c. Reasonable Alternatives
The claimant voluntarily quit for valid circumstances when he had serious, documented medical reasons for leaving the job. The only alternative available to the claimant was an unpaid leave of absence. The Board has held that an unpaid leave of absence for an indefinite period of time is not a reasonable alternative under Section 8-1001. Since the claimant had no reasonable alternative, he had valid circumstances for leaving. Washington v. University of Maryland Medical System, 1079-BR-91.

The claimant's back problems were aggravated by the conditions of her employment. She has a valid circumstance for leaving the employment because she had no reasonable alternative other than to quit. The claimant's condition does not amount to good cause because there is no evidence that the duties of her position were any more onerous than would normally be expected in such a job. Arnold v. Friends Lifetime Care Baltimore, 767-BH-93.

d. Health of Another Individual
The claimant's husband was in an automobile accident and he developed disk problems and arthritic problems in his spine. His doctor recommended that he move to Tennessee for the drier climate and the company of his relatives. The claimant resigned to go with her husband and take care of him. The claimant's spouse was ambulatory and could drive a car, but he did need to have continuing surgery on his spine and the claimant was required to drive him to the doctor's office every other night. The claimant's spouse's inability to work, the requirement that the claimant take him to the doctor every other night, and the necessity for further surgery constituted valid circumstances for the claimant's leaving her employment. Hurd v. Franklin Square Hospital, 684-BR-87.

The claimant took a leave of absence to care for her seriously ill father. When she realized she needed a longer leave of absence, she requested this from the employer, but her request was denied. No other family members were available to assist the claimant's father. The claimant subsequently resigned. The claimant produced medical documentation of her father's condition. The claimant voluntarily quit without good cause, but with valid circumstances. Leonard v. Sinai Hospital of Baltimore, 129-BH-91.

The claimant provided medical evidence that her daughters were ill, however, the claimant's situation was not necessitous or compelling. The claimant voluntarily quit without good cause or valid circumstances. Jenkins v. Echelon Service Company, 1573-BR-91.

e. Pregnancy
Although the claimant was pregnant, she was fully capable of working, but did not wish to work anymore. The claimant quit without valid circumstances. Gault v. Werner's, Inc., 24-BR-87.

The immediate cause of the claimant's quitting was her physical inability to work, due to her pregnancy. In this case, there were no reasonable alternatives available to the claimant at the time she became disabled. She quit with valid circumstances. Woods v. Triple Crown Restaurant, Inc., 616-BR-89.

5. Babysitting Problems
The claimant was required to abruptly change the shift that she worked for years and did not have a chance to change her child care arrangements. She had a valid circumstance for leaving. Young v. Evergreen Health Group, 31-BR-88.

The claimant continued to work until she took a leave of absence because of her advanced stage of pregnancy. In November, she told the employer she would return to work in January, but placed restrictions on the time and days she would work, since she could only get a babysitter for certain hours and days. The employer could not accommodate her. Her leaving was without good cause or valid circumstances. Hilderbrand v. NMCS, Inc., 549-BR-88.

The claimant, who quit her job due to the unexpected loss of her babysitter, had no alternative but to leave. The claimant was unable to find another babysitter and was not eligible for a leave of absence. The claimant quit without good cause, but with valid circumstances. Bond v. Rosewood Center, 770-BR-90.

The claimant quit when her day care was involuntarily terminated. The claimant made a reasonable attempt to find alternative care on short notice, but found it too late to keep the job. The claimant voluntarily quit without good cause, but with valid circumstances. Morrison v. Halper Eye Associates, 292-BR-91.

The claimant voluntarily quit because he had no one to care for his daughter during the evening hours. Quitting one's job due to child care problems is not good cause, but can be valid circumstances if the situation is compelling or necessitous and there is no reasonable alternative to quitting. The claimant's situation meets these standards. The claimant voluntarily quit without good cause, but with valid circumstances. Norman v. Esskay, Inc., 470-BR-91.

6. Incarceration
A claimant who is incarcerated, but who is later released without having been convicted of a crime, has not voluntarily quit his job, provided that he has appropriately notified his employer of his absence. Lansinger v. Baltimore County Fire Department, 1305-BR-82.

Where the claimant was requested to contact his employer after his trial, but did not do so, and where he also failed to contact his employer upon the expiration of his three-day jail sentence, his job abandonment was a voluntary quit, without good cause or valid circumstances. Hicks v. Francis Scott Key Medical Center, 976-BR-85.

7. Leaving to Accompany or Join a Spouse
NOTE: See Section II.B.2.