Vital
Support Home Health Care Agency v. UCBR – Cmwlth. Court – Feb. 24, 2017 –
unreported memorandum decision
Claimant
had good cause to quit her job as home health aid where, after her long-time
client moved, employer offered her only on-call work with only one-hour advance
notice. Claimant had three young
children and needed child care.
The
inability to find childcare on short notice, with communication to the
employer, may constitute a necessitous and compelling cause for voluntarily
terminating employment. Truitt v. UCBR, 589 A.2d 208, 210 (Pa. 1991); Blakely
v. UCBR, 464 A.2d 695, 696 (Pa. Cmwlth. 1983). However, generally in order to
justify quitting based on lack of childcare, a claimant must establish that he
or she exhausted all other alternative childcare arrangements before
voluntarily terminating employment. Beachem v. UCBR, 760 A.2d 68, 72 (Pa.
Cmwlth. 2000). Claimant did so in this
case
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*An unreported Commonwealth Court case may not be
cited binding precedent but can be cited for its persuasive value. See 210 Pa. Code § 69.414(b) and Pa. R.A.P. 3716
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