Care of Children or Home
Care of Minor Child or Children
Arranging child care is an integral part of the arrangements a claimant having small children who need care, must make, in order to work. Thus, before good cause may be found it must be shown that the claimant was left with no practical alternative to quitting.
If there is no practical alternative
, the necessity of providing child care is considered to be compelling.
Under normal circumstances arranging care with neighbors, relatives, friends, a nursery school, or day care service are considered practical alternatives to quitting. Therefore, faced with loss of existing child care, a claimant would generally be expected to explore all of these alternatives prior to quitting. Where the loss of existing child care is only temporary, a claimant would logically be expected to cope with child care arrangements that might be less than satisfactory on a permanent basis. For example, the cost may be higher, distance from home, or work farther, etc.
P-B-237 is illustrative of a situation where the claimant had no other practical alternative to quitting his job. The claimant quit his job in California to establish his residence with his parents in Pennsylvania. The claimant had become separated from his wife and consequently had no one except his mother to care for his two minor children. In finding the claimant eligible for benefits, the Board stated:
". . . The claimant had the sole responsibility of caring for his two small children when he became separated from his wife. Consequently the need of caring for these minor dependents made it mandatory for him to leave his work, and since the claimant had no one to furnish this care where he was living he found it necessary to return to the home of his parents in Pennsylvania where his mother could assume the responsibility.
Under these circumstances and in accordance with many prior holdings of this Board, we conclude that the claimant had a sufficiently compelling reason for leaving his employment in California
. . . ."
The key factors in this case are that the children were very young and the claimant had no one to care for them where he was living. While he might have secured a leave, taken his children to his mother in Pennsylvania and then returned to work, this would have meant abandonment of his children. A finding of good cause does not require a claimant to go to such extremes.
The cost of supplying child care is usually not a consideration in deciding if a claimant had good cause for quitting
. The fact that a claimant does not consider it "economically worthwhile" to continue working is not, of itself, good cause for quitting.
However, special circumstances may arise where the claimant would be required to expend an exceptional and unreasonable amount for child care. Such special circumstances would usually involve transfer to different locations or assignments to split shifts.
In the case of juvenile delinquents, government authorities frequently will order parents to remain home at night to exercise personal parental authority over the child. The degree of compulsion is very strong in such cases and usually the parent cannot make other arrangements to solve the problem. Accordingly, when a claimant quits because the hours of work would not permit him or her to comply with such a directive, the quit will normally be with good cause.
In P-B-246, the claimant worked a split shift as a telephone operator. She had child care on a 24-hour basis for her infant child, but the nursery home refused to care for the child after learning that it had been exposed to measles through its father. The claimant told the employer of the emergency requiring her to leave, and asked if she could be assigned to night work so she could continue working. The employer did not grant the request for night work or offer the claimant a leave of absence. In holding the claimant eligible the Board stated:
"Although the employer had a leave of absence policy in effect the evidence shows that the employer did not inform the claimant thereof prior to her leaving nor did the employer offer to grant one to the claimant despite her efforts and willingness to continue working. Under the circumstances herein the claimant did everything that could be reasonable expected of her to preserve her position prior to leaving it and the employer did nothing to aid her in such effort."
If the claimant's problem can be solved by transfer to another shift or locality, the claimant would be expected to attempt to make such arrangements before good cause could be found for quitting.
Other Domestic Obligations
A quit for the sole purpose of remaining home to perform household duties may be understandable but will seldom, if ever, be compelling. Consequently, a quit for such a purpose will be without good cause unless other circumstances are present which make the quit compelling, such as care for ill children or other family members.