## Facts

- Karen A. Davis worked for Equifax in Tacoma, Washington for 13 years.
- Davis was in a long-term relationship with Andrew Stephens in Port Angeles; they visited weekly for six years and organized aspects of their lives similarly to spouses.
- Davis quit her job to move from Tacoma to Port Angeles to live with Stephens; they had no immediate plans to marry.
- Before resigning, Davis sought a transfer to the Port Angeles office and a leave of absence; both requests were denied.
- Davis applied for unemployment benefits; the Department of Employment Security denied benefits for voluntary quit without good cause.
- Administrative appeals and the superior court affirmed the denial; the Washington Supreme Court reviewed the agency action.

## Issues

1. Whether quitting employment to relocate and live with an unmarried partner qualifies as “good cause” under RCW 50.20.050, including the statutory exception tied to “marital status” or “domestic obligations.”
2. Whether limiting that marital-status exception to legally married persons violates equal protection.

## Decision

- The Washington Supreme Court affirmed the denial of unemployment benefits.
- Davis’s reason for quitting was personal and not causally connected to the employment; it did not constitute statutory “good cause.”
- The “marital status” exception in RCW 50.20.050 applies to legal marriage and does not extend to meretricious (nonmarital cohabiting) relationships.
- Treating legally married claimants differently from unmarried cohabitants for this exception survives rational-basis review and does not violate equal protection.

## Legal Principles

- Under Washington’s Employment Security Act, “good cause” for a voluntary quit generally requires a work-connected reason related to employment conditions, not purely personal motivations.
- Statutory exceptions based on “marital status” are construed to refer to legal marital status; courts will not extend the exception to nonmarital cohabitation absent legislative language.
- Differential treatment of married and unmarried individuals in allocating unemployment benefits is permissible if rationally related to legitimate governmental interests, including encouraging legal marriage.

## Conclusion

A claimant who resigns to relocate and cohabit with an unmarried partner is disqualified from unemployment compensation absent a work-related reason for quitting, and the Legislature may constitutionally confine the marital-status exception to legally married spouses.


Davis v. Dep’t of Emp. Sec., 108 Wn.2d 272, 737 P.2d 1262 (Wash. 1987)