Yesterday the Superior Court of New Jersey, Appellate Division, decided a case involving an employee who voluntarily quit her job due to work-related stress and was then turned down for unemployment benefits.
The employee worked as a claims adjuster until May 2007, when she quit. Two months earlier, her job duties had increased because a co-worker went out on disability.
She argued that she left work because of mental health issues that began when her mother died and that worsened with her work-related stress. Both the Appeal Tribunal and the Board of Review found that she left without good cause attributable to her work and that as a result, she could not qualify for unemployment benefits. the test for whether a decision to quit work constitutes good cause is one of ordinary good sense and prudence.
Under the law, the employee needs to do whatever is necessary and reasonable to stay employed.
To show that a pre-existing medical condition was aggravated by a workplace situation, the claimant must show competent medical evidence as to that assertion. The evidence must be more than an equivocal statement.
In this case, the claimant presented evidence of an ER visit two years before she left work in which she told the nurse that she had stress at work and she had thoughts of killing her boss. In addition, the ER records reflected her complaints about financial and housing problems.
The court pointed out that the employee stayed in her job for two years after her ER visit, which damaged her contention that it was the work-related stress that made her quit work.
The Appellate Division agreed with the Appeal Tribunal and the Board of Review and concluded that the employee was not eligible for unemployment benefits since she left work without good cause attributable to her work.