MacGregor v. Unemployment Insurance Appeals Board
37 Cal. 3d 205, 207 Cal. Rptr. 823, 689 P.2d 453 (1984)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
An employee who voluntarily leaves employment to accompany a nonmarital partner and their child to a new residence in order to preserve the family unit has done so with "good cause" and is therefore eligible for unemployment insurance benefits.
Facts:
- Patricia MacGregor worked as a waitress in Santa Clara, California.
- MacGregor lived with Dick Bailey, to whom she was engaged, and in February 1980, they had a child together, Leanna.
- The three lived together as a family unit, and Bailey acknowledged his paternity.
- In April 1980, Bailey decided the family should move to New York to care for his ill, 76-year-old father who lived alone.
- Bailey's father had asked the family to come live with and care for him.
- In May 1980, MacGregor informed her employer that she would not be returning to work from her pregnancy leave due to the family's relocation.
- In June 1980, MacGregor, Bailey, and their daughter moved into Bailey's father's home in New York.
- After moving, MacGregor was unable to find new employment.
Procedural Posture:
- MacGregor applied for unemployment benefits with the California Employment Development Department, which determined she was ineligible.
- MacGregor appealed to an administrative law judge, who affirmed the department's denial.
- MacGregor appealed to the California Unemployment Insurance Appeals Board (the Board), which adopted the administrative law judge's decision.
- MacGregor filed a petition for a writ of mandate in the Santa Clara Superior Court (a trial court).
- The superior court exercised its independent judgment, found MacGregor had good cause to leave her job, and issued a writ ordering the Board to set aside its decision.
- The Board, as appellant, appealed the superior court's judgment.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a worker who leaves her employment to relocate with her nonmarital partner and their child, in order to preserve the family unit, voluntarily leave work with 'good cause' under the unemployment insurance statute?
Opinions:
Majority - Reynoso, J.
Yes. A worker who leaves her employment to preserve a family unit with her nonmarital partner and their child has voluntarily left work with 'good cause.' The court's previous decision in Norman left open the possibility that compelling circumstances, beyond just a nonmarital relationship, could establish good cause. The presence of a child and the need to preserve the fundamental family unit created by two parents and their natural child constitutes such a compelling circumstance. The state's public policy of protecting the parent-child relationship is as strong as its policy favoring marriage. Unlike cases involving only a nonmarital relationship, the existence of a family unit with a child is an objectively verifiable fact that avoids difficult problems of proof regarding the nature of the relationship. Therefore, MacGregor's decision to relocate with her partner and child to preserve their family unit was a compelling reason that qualifies as good cause for leaving her job.
Analysis:
This decision significantly clarifies and expands the 'good cause' standard for unemployment eligibility in the context of nonmarital relationships, building upon the court's precedent in Norman. It shifts the legal analysis from the formal marital status of the partners to the functional reality of their family unit, particularly when a child is involved. By recognizing a family unit based on parentage and cohabitation, the court broadens the definition of 'family' for purposes of unemployment law. This precedent ensures that the law protects the stability of parent-child relationships regardless of the parents' marital status and will influence future cases involving domestic obligations as a reason for leaving employment.
Unlock the full brief for MacGregor v. Unemployment Insurance Appeals Board