Whether an applicant's reason for quitting constitutes a good reason caused by the employer is a question of law that we review de novo, so long as the conclusion is based on factual findings that are supported by substantial evidence in the record. Thao v. Command Ctr., Inc., 824 N.W.2d 1, 4 (Minn.App. 2012). Substantial evidence is "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion."
She relies on caselaw holding that a substantial wage or hour reduction can provide good reason to quit. Specifically, she relies on Thao v. Command Ctr., Inc., 824 N.W.2d 1 (Minn. App. 2012); Sunstar Foods Inc. v. Uhlendorf, 310 N.W.2d 80 (Minn. 1981); Scott v. Photo Ctr., Inc., 306 Minn. 535, 235 N.W.2d 616 (1975); and Haugen v. Superior Dev., Inc., 819 N.W.2d 715 (Minn. App. 2012).
An employee is not required to complain to an employer or give them an opportunity to correct a breach of an employment agreement before quitting. Thao v. Command Ctr., Inc., 824 N.W.2d 1, 11 (Minn. App. 2012) (holding that employee need only complain when confronted with "adverse working conditions," which do not include "terms of employment that are contractual in nature"). Phelps relies exclusively on Hayes as authority for his argument that employer's change in the employment agreement constituted good cause for Phelps to terminate the employment.
Thao v. Command Ctr., Inc., 824 N.W.2d 1, 4 (Minn.App. 2012). However, we review the "ULJ's factual findings in the light most favorable to the decision and will not disturb them when they are supported by substantial evidence." Id.
Whether an applicant's reason for quitting constitutes a good reason caused by the employer is a question of law that we review de novo; the ULJ's conclusion must be based on factual findings that are supported by substantial evidence in the record. Thao v. Command Ctr., Inc., 824 N.W.2d 1, 4 (Minn.App. 2012). A good reason caused by the employer is defined exclusively by statute.
Id. The ULJ's conclusion as to whether an employee is eligible for unemployment benefits is a question of law, to which we apply a de novo standard of review. Thao v. Command Ctr., Inc., 824 N.W.2d 1, 4 (Minn. App. 2012). A.
"Generally, a substantial pay reduction gives an employee good cause for quitting." Thao v. Command Ctr., Inc., 824 N.W.2d 1, 5 (Minn. App. 2012) (quotation omitted). But unlike the relator in Rootes, Noel did not face a choice between quitting or accepting a lower salary.
Oct. 1, 2008). The ULJ's ineligibility determination and the determination that an employee quit without good reason attributable to the employer, are legal conclusions which this court reviews de novo. Thao v. Command Ctr., Inc., 824 N.W.2d 1, 4 (Minn. App. 2012). II. The ULJ did not err in determining that relator is ineligible for unemployment benefits because he did not quit for a good reason caused by his employer.
"The determination that an employee quit without good reason attributable to the employer is a legal conclusion, which this court reviews de novo." Thao v. Command Ctr., Inc., 824 N.W.2d 1, 4 (Minn. App. 2012). The statute defines a good reason caused by the employer 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."
And if the employee is subject to a significant unilateral change in the terms of employment, such as a significant reduction in hours, and quits without first complaining to the employer, that employee may retain eligibility for benefits. Thao v. Command Ctr., Inc., 824 N.W.2d 1, 11 (Minn. App. 2012). Shah argues that IMI's breached her employment contract, giving her good reason to quit, because it scheduled her to work on Fridays twice, once in May and once in June, contrary to her employment agreement.