NC court sets standard for denying jobless benefits in equivocal circumstances

North Carolina employers should be aware of a recent North Carolina Court of Appeals decision regarding unemployment insurance benefits. When analyzing whether a former employee's termination was voluntary or involuntary—and, by extension, whether he is eligible for unemployment benefits—the court clarified the issue must be resolved by determining whether a reasonable person would have believed he resigned.

North Carolina unemployment law primer

North Carolina's unemployment insurance system is intended to assist eligible employees who become unemployed through no fault of their own. The system is funded through a tax on employer payrolls, from which unemployment benefits are paid to qualified unemployed workers.

Importantly, not everyone who applies qualifies for unemployment benefits, and certain conditions must be met to get and remain eligible for them. Under North Carolina law, individuals are disqualified from receiving benefits if they “left work” for a reason other than good cause attributable to the employer. The term “left work” means the employee resigned and wasn't terminated by the employer.

Facts

Todd Maness, a law enforcement officer, failed to abide by an order from his superiors to disclose his personal medical history to an outside company hired by the police department to conduct medical screenings of its officers. Specifically, Maness told his superiors he wouldn't provide the information. Instead, he turned in his badge and went home.