This opinion will be unpublished and
may not be cited except as provided by
Minn. Stat. § 480A.08, subd. 3 (2014).
STATE OF MINNESOTA
IN COURT OF APPEALS
A14-2142
Angela Watson,
Relator,
vs.
St. Stephen’s Human Services, Inc.,
Respondent,
Department of Employment and
Economic Development,
Respondent
Filed August 3, 2015
Affirmed
Chutich, Judge
Department of Employment and Economic Development
File No. 32856325-3
Angela Watson, Columbia Heights, Minnesota (pro se relator)
St. Stephen’s Human Services, Minneapolis, Minnesota (respondent)
Lee B. Nelson, Department of Employment and Economic Development, St. Paul,
Minnesota (for respondent department)
Considered and decided by Kirk, Presiding Judge; Connolly, Judge; and Chutich,
Judge.
UNPUBLISHED OPINION
CHUTICH, Judge
Relator Angela Watson challenges an unemployment-law judge’s determination
that she is ineligible for unemployment benefits. She claims that (1) it was medically
necessary for her to quit, (2) she was subject to adverse work conditions that her
employer did not correct, and (3) she should have been afforded the opportunity to
present additional evidence. Because quitting was not medically necessary, any adverse
work conditions did not justify quitting, and Watson had an opportunity to present
evidence, we affirm.
FACTS
In 2007, Watson began working for respondent St. Stephen’s Human Services,
Inc. as a shelter advocate. Transitional changes at St. Stephen’s caused Watson to
become stressed, and she struggled with insomnia, heart palpitations, and difficulty
focusing. Despite these issues, Watson liked working at St. Stephen’s.
In August 2014, Watson suffered a panic attack and went to the emergency room.
Emergency-room personnel told Watson that panic attacks are common for people in her
line of work, gave her medication, and told her to follow up with a medical professional.
The next day, Watson met with St. Stephen’s human-resources director and gave
the director information about her health. During this meeting, Watson decided that she
should leave St. Stephen’s, and the director agreed that her decision was for the best.
Watson’s employment ended on September 2, 2014.
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On September 18, the Minnesota Department of Employment and Economic
Development (the department) determined that Watson was ineligible for unemployment
benefits, finding that Watson’s health problems did not require her to quit. Watson
appealed this determination.
After a hearing, the unemployment-law judge denied Watson benefits. He found
that Watson quit her employment and that no exception allowed Watson to receive
benefits. Watson requested reconsideration, and the unemployment-law judge affirmed
his decision. Watson appealed by a writ of certiorari.
DECISION
The purpose of the Minnesota Unemployment Insurance Program is to assist those
who become unemployed through no fault of their own. Minn. Stat. § 268.03, subd. 1
(2014). Chapter 268 is remedial in nature and must be applied in favor of awarding
unemployment benefits. Minn. Stat. § 268.031, subd. 2 (2014). Any provision
precluding an applicant from benefits must be narrowly construed. Id.
On review, we may affirm the decision of an unemployment-law judge or remand
the case for further proceedings; we may also reverse or modify the decision if the
substantial rights of the relator have been prejudiced because the findings, inferences,
conclusion, or decision is affected by an error of law or unsupported by substantial
evidence in view of the record as a whole. Minn. Stat. § 268.105, subd. 7(d) (2014).
We view an unemployment-law judge’s factual findings in the light most
favorable to the decision, and the findings will not be disturbed if the evidence
substantially sustains them. Skarhus v. Davanni’s Inc., 721 N.W.2d 340, 344 (Minn.
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App. 2006). But whether an employee who quits falls within an exception making her
eligible for unemployment benefits is a question of law reviewed de novo. Peppi v.
Phyllis Wheatley Cmty. Ctr., 614 N.W.2d 750, 752 (Minn. App. 2000).
I. Medically Necessary
Watson first argues that the unemployment-law judge erred by determining that it
was not medically necessary for her to quit. We disagree.
Minnesota law provides that an applicant who quits her employment is ineligible
for unemployment benefits unless an exception applies. Minn. Stat. § 268.095, subd. 1
(2014). One exception to this general rule is that an applicant may receive
unemployment benefits if “the applicant’s serious illness or injury made it medically
necessary that the applicant quit.” Id., subd. 1(7). But this exception applies only “if the
applicant informs the employer of the medical problem and requests accommodation and
no reasonable accommodation is made available.” Id.
Here, the unemployment-law judge found that quitting was not medically
necessary. He found that Watson had a panic attack and was treated, suffered from
insomnia and heart issues, and was advised that she worked in a high-stress occupation.
But she was never told that quitting was medically necessary. He also found that Watson
quit before getting any follow-up treatment or medical guidance.
The unemployment-law judge’s findings are supported by substantial record
evidence, and Watson does not contend that the factual findings are incorrect. These
findings support a conclusion that Watson is ineligible for unemployment benefits.
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To obtain unemployment benefits, Watson’s illness or injury must have made it
medically necessary that she quit. See id. No evidence suggests that she was informed at
the hospital that her condition required her to leave her employment. Instead, emergency
room personnel instructed her to seek follow-up treatment. And rather than wait to make
her decision until after this follow-up treatment, Watson decided to leave St. Stephen’s
the next day. While Watson’s condition may have been serious, no evidence exists to
demonstrate that the condition made it medically necessary for her to leave her
employment.
Although we are sympathetic to the stress that Watson no doubt experienced in
this difficult occupation, we nevertheless conclude that the unemployment-law judge did
not err by concluding that Watson did not need to quit because it was medically
necessary.
II. Good Reason Caused by Employer
Watson next argues that she is eligible for unemployment benefits as she quit
because of a good reason caused by her employer. This argument is also without merit.
An applicant may receive unemployment benefits if the applicant quit because of
“a good reason caused by the employer . . . .” Id., subd. 1(1). “Good reason caused by
the employer” is defined as “a reason: (1) that is directly related to the employment and
for which the employer is responsible; (2) that is adverse to the worker; and (3) that
would compel an average, reasonable worker to quit and become unemployed rather than
remaining in the employment.” Id., subd. 3(a) (2014). In this context, to “compel is ‘[t]o
cause or bring about by force, threats, or overwhelming pressure.’” Werner v. Med.
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Prof’ls, 782 N.W.2d 840, 842 (Minn. App. 2010) (alteration in original) (quoting Black’s
Law Dictionary 321 (9th ed. 2009)), review denied (Minn. Aug. 10, 2010). This analysis
must be applied to the specific facts of each case. Minn. Stat. § 268.095, subd. 3(b)
(2014).
“If an applicant was subjected to adverse working conditions by the employer, the
applicant must complain to the employer and give the employer a reasonable opportunity
to correct the adverse working conditions before that may be considered a good reason
caused by the employer for quitting.” Id., subd. 3(c) (2014). Whether an employee had a
good reason to quit caused by the employer is a question of law reviewed de novo.
Rowan v. Dream It, Inc., 812 N.W.2d 879, 883 (Minn. App. 2012). “While an employee
may have a good personal reason for quitting, it does not necessarily constitute a good
reason caused by the employer for quitting.” Werner, 782 N.W.2d at 842.
The unemployment-law judge found that Watson was stressed from conditions at
work because of the nature of the job and some organizational changes. He also found
that she liked her job and the people with whom she worked and that she did not
understand how work aggravated her medical issues. He determined that the evidence
did not support a conclusion that the conditions would compel an average, reasonable
worker to quit.
The threshold for considering stress a good reason to quit caused by the employer
is high. “Good reason to quit caused by the employer” does not encompass situations
“where the employee is simply frustrated or dissatisfied with [her] working conditions.”
Portz v. Pipestone Skelgas, 397 N.W.2d 12, 14 (Minn. App. 1986). In Zepp v. Arthur
6
Treacher Fish and Chips, the supreme court found good reason to quit caused by the
employer where the employee’s work hours more than doubled and “the employer made
unreasonable demands of [the] employee that no one person could be expected to meet.”
272 N.W.2d 262, 263 (Minn. 1978). Similarly, in Porrazzo v. Nabisco, Inc., we
concluded that the employee had good reason to quit where the employee’s hours
substantially increased, he was assigned responsibility for two of the three work shifts,
not all of his overtime hours were paid, his vacation requests were denied, and he was
subjected to a harassing, unworkable relationship with his supervisor. 360 N.W.2d 662,
663-64 (Minn. App. 1985).
Here, the unemployment-law judge denied benefits because he concluded that the
stress at St. Stephen’s would not compel a reasonable person to quit her employment.
This conclusion is correct. Although some evidence showed that structural changes at
work caused Watson stress, nothing suggests that her increased workload escalated to the
levels found in Zepp or Porrazzo such that a reasonable person would leave. Nor does
any evidence show that the pressure on Watson was overwhelming so as to compel her to
quit. See Werner, 782 N.W.2d at 842.
Watson’s testimony focused more on the stressful nature of her job rather than
stress because of increased responsibilities. And the stressful nature of a job cannot meet
this statutory quit exception: it must be stress for which the employer is responsible. See
Minn. Stat. § 268.095, subd. 3(a). No authority supports the proposition that an employer
is responsible for stress caused by employment that is inherently stressful.
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On this point, Watson also notes that St. Stephen’s did not contest her receiving
unemployment benefits. But agreements between applicants and employers regarding
unemployment benefits are not binding on the determination of eligibility for benefits.
Minn. Stat. § 268.069, subd. 2 (2014). An agreement between an applicant and an
employer cannot establish an applicant’s eligibility for benefits. Scheeler v. Sartell Water
Controls, Inc., 730 N.W.2d 285, 288 (Minn. App. 2007). This argument fails.
III. Additional Evidence
Watson finally argues that the decision must be reversed because she was not
permitted to submit additional evidence to support her claim. We are unpersuaded by
this contention.
Minnesota law provides that on a request for reconsideration, an unemployment-
law judge may not consider any additional evidence except to determine whether an
additional hearing is necessary. Minn. Stat. § 268.105, subd. 2(c) (2014). An additional
hearing must be ordered if a party shows that previously unsubmitted evidence would
likely change the outcome and good cause existed for not submitting the evidence. Id.
An additional hearing must also be ordered if a party shows that unsubmitted evidence
would demonstrate that evidence admitted at the hearing is likely false and that false
evidence had an effect on the outcome. Id.
Here, the unemployment-law judge informed Watson that the hearing was her
opportunity to present evidence. When asked if she had more information that she
wanted to present, Watson offered no evidence. After reviewing the exhibits with the
unemployment-law judge, Watson said that “you guys have everything, yes.”
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Watson claims that, had she been permitted to submit additional evidence in her
request for reconsideration, the unemployment-law judge would have ordered an
additional hearing. But in her request for reconsideration, Watson did not say that the
decision should be reconsidered because of additional evidence, she simply stated that
she “d[id] not agree with the decision.” Watson was not barred from submitting evidence
to show that an additional hearing was necessary, but she did not do so. Because the
unemployment-law judge gave Watson the opportunity to present evidence, this claim
does not have merit. See Lawrence v. Ratzlaff Motor Express Inc., 785 N.W.2d 819, 824
(Minn. App. 2010) (holding that the unemployment-law judge adequately developed the
record where the parties had “ample opportunity” to present evidence), review denied
(Minn. Sept. 29, 2010).
Affirmed.
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Angela Watson, Relator v. St. Stephen's Human Services, Inc., Department of Employment and Economic Development
Combined Opinion