Thursday, August 24, 2006

UC - voluntary quit - elimination of health care benefits

Brunswick Hotel & Conference Center v. UCBR - Commonwealth Court - August 23, 2006

http://www.courts.state.pa.us/OpPosting/CWealth/out/464CD06_8-23-06.pdf

Claimant had good cause to quit her job when employer eliminated health care benefits that had previously been provided to her. Claimant continued to work for 8 months after this happened, showing that she made a reasonable effort to preserve her job.

The court contrasted this case, involving a total elimination of health care benefits, with cases where the cost of health insurance had increased -- Steinberg v. UCBR, 624 A2d 237 (Pa. Cmwlth. 1993) and Chavez v. UCBR, 738 A2d 77 (Pa. Cmwlth. 1999). Even in those cases, benefits were granted where the increased cost was a "substantial unilateral change," noting however that there was "no talismanic percentage for determining a change so substantial as to warrant" good cause to quit.