Washington Supreme Court Holds That Statutory List of "Good Cause" Reasons to Quit Are Not Exclusive, Further Opening the Door For Claimants to Claim Unemployment Benefits After They Voluntarily Quit


On June 19, 2008, the Washington State Supreme Court issued its decision in Spain v. Employment Sec. Dep’t, unanimously ruling that the statutory list of non-disqualifying reasons for voluntarily quitting work contained in former RCW 50.20.050(2)(b)(i) through (x) is not an exclusive list for establishing eligibility for unemployment benefits. The Supreme Court reasoned that the statute, as written, does not show clear legislative intent to limit eligibility for unemployment benefits to individuals who voluntarily quit work for one of the non-disqualifying reasons listed in the statute.

Legislative History

Historically, unemployment benefits have been reserved for individuals who become unemployed through no fault of their own, and are otherwise willing, available and seeking to work. In 2005, the Washington legislature provided a list of ten specific reasons why an employee may voluntarily quit and still be eligible for unemployment benefits. As of the 2008 Legislative Session, there are now eleven listed reasons, including disability, a military spouse’s relocation, protection from domestic violence and a substantial reduction in pay or hours. RCW 50.20.050(2)(b) (2008). The 2005 legislation retained the original text of subsection (a), providing that an individual is disqualified from benefits if he or she “has left work voluntarily without good cause.”

Since 2005, the legislature, the Employment Security Department (“ESD”) and employers generally have interpreted the list of specific reasons in RCW 50.0.050(2)(b) as establishing the only “good cause” reasons for former employees to voluntarily quit work and maintain their eligibility for unemployment benefits.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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