In Idaho, if you leave your job voluntarily (rather than being fired), you are not eligible for unemployment benefits unless you left for “good cause connected with [your] unemployment.” The term “good cause” does not have an exact definition, and what constitutes good cause will depend on the unique facts of each individual case, but an employee’s decision to quit must be based on circumstances that are “real, not imaginary, substantial not trifling, and reasonable, not whimsical.” Ullrich v. Thorpe Elec., 109 Idaho 820, 823, 712 P.2d 521, 524 (1985). Also, rather than quit, an employee must explore viable options to resolve work problems and keep his job. See Ellis v. Northwest Fruit & Produce, 103 Idaho 821, 654 P.2d 914 (1982). And if he does quit, an employee must prove that good cause existed (the employer does not have to prove that good cause did not exist).
Over the past several decades, Idaho courts have determined that employees did not have good cause to quit under the following circumstances:
- A man employed as a pole maker was not sure if he would have enough work after a six-day lay-off due to weather conditions, so he quit. Conrad v. Altmiller, 89 Idaho 214, 404 P.2d 337 (1965).
- A ski lift operator quit his job because the transportation his employer provided to get to him to work gave him motion sickness, and he wasn’t given enough work shifts to pay for his own transportation. The employee accepted the job knowing he’d get motion sickness, and there was no evidence his hours and pay were worse than similar jobs in the area. Clark v. Bogus Basin Recreational Ass’n, 91 Idaho 916, 435 P.2d 256 (1967).
- A man hired as a fire fighter quit his job because he learned he would be assigned to the “brush crew,” which lived away from town in a logging camp. This living arrangement would not be harmful to his mental or physical health. McMunn v. Department of Public Lands, 94 Idaho 493, 491 P.2d 1265 (1971).
- An automobile upholster quit his job because he believed his boss questioned his honesty. Rogers v. Trim House, 99 Idaho 746, 588 P.2d 945 (1979).
- Rather than quitting his job, an employee should have discussed with his boss how his back problem was aggravated by the work, and he should have discussed his disappointment in not being given the sales job he thought he’d been hired to do. Ellis v. Northwest Fruit & Produce, 103 Idaho 821, 654 P.2d 914 (1982).
- Two co-workers at the sheriff’s office fell in love and decided to get married, but the office had a policy prohibiting married couples from working there. After the couple married, the husband resigned, and the wife resigned five days thereafter. The wife did not have good cause to resign because her marriage did not violate the office policy at the time she resigned. Berger v. Nez Perce Sheriff, 105 Idaho 555, 671 P.2d 468 (1983).
- A janitor quit without good cause after the principal told him he’d be put on probation and fired at some point in the future if his performance didn’t improve. Hart v. Deary High Sch., 126 Idaho 550, 887 P.2d 1057 (1994).
- A dietary manager quit due to an uncomfortable work environment, delay in allowing him to return to work after a medical leave, tension with his supervisor, and other work problems that would not compel the average person to quit. Buckham v. Idaho Elk’s Rehab. Hosp., 141 Idaho 338, 109 P.3d 726 (2005).
- A car salesman quit after claiming a hostile work environment and gender, age, and disability discrimination, but she never attempted to go beyond her immediate supervisors to resolve her concerns. Higgins v. Larry Miller Subaru-Mitsubishi, 145 Idaho 1, 175 P.3d 163 (2007).
- An employee quit after developing wrist pain from tasks at work, but she could still perform her work duties and simply needed to wear a brace. Poledna v. Idaho Dep’t of Labor, 347 P.3d 1186 (2015).
On the other hand, good cause for quitting a job may exist under facts similar to the following:
- An employer withheld over $100 from an employee’s paycheck, and the employee was unsuccessful in obtaining an explanation for this withholding, so he quit. Smith v. Johnson’s Mill, 96 Idaho 760, 536 P.2d 755 (1975).
- An employee quit after receiving a severe reduction in work hours. (However, a part-time employee who refuses to accept full-time work does not have good cause to quit after her hours are somewhat reduced). Stone v. South Hill Chevron, 99 Idaho 162, 578 P.2d 1093 (1978).
- A dental assistant who made dentures quit because her boss was going to deduct fifty cents from her check for every five minutes he had to spend fixing her denture work, a policy that was “clearly illegal.” Wood v. Quali-Dent Dental Clinics, 107 Idaho 1020, 695 P.2d 405 (1985).
- A truck driver quit after his wages were reduced by more than 50%. Kyle v. Beco Corp., 109 Idaho 267, 707 P.2d 378 (1985).
- A shoe salesman’s boss interrogated her in a heavy-handed and offensive manner, intimidating her on unfounded charges of theft from the store. She correctly believed that she was about to be fired, so she quit. Bortz v. Payless Drug Store, 110 Idaho 942, 719 P.2d 1202 (1986).
- An employee at the county assessor’s office quit when he believed he had been hired for another job, even though this job fell through. Employment Security Act. Schafer v. Ada County Assessor, 111 Idaho 870, 728 P.2d 394 (1986).
- After an employee reported an incident of sexual harassment to management, her supervisor retaliated against her, and she experienced health problems under this stress and ultimately quit. Reedy v. M.H. King Co., 128 Idaho 896, 920 P.2d 915 (1996).
- An employee at Melaleuca quit after her supervisor reduced the amount of her raise because he disagreed with her decision to return to work after her child was born. Moore v. Melaleuca, Inc., 137 Idaho 23, 43 P.3d 782 (2002).
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