## Facts

- Mary Holbrook was hired in 1981 as a part-time curatorial assistant at the Minnesota Museum of Art, with assurances that research would be a significant component of her work.
- For several years she performed mainly clerical tasks; in 1983 she complained in writing and requested additional research- and collection-related responsibilities.
- She was promoted to assistant curator and her hours increased; by 1985 most of her time was spent on research and documentation, though she still performed some clerical work due to lack of departmental support staff.
- In 1985, due to funding limitations, the museum eliminated her assistant curator position and offered reassignment to two half-time positions in other departments that were primarily clerical in nature.
- The museum indicated that if she accepted the clerical positions, it would conduct a review in three months and the positions might be upgraded.
- Holbrook refused the reassignment and left when her assistant curator job ended, then applied for unemployment benefits.
- A claims deputy found her eligible; after the employer’s appeal, a referee and then the Commissioner of Jobs and Training determined she quit voluntarily without good cause attributable to the employer.

## Issues

1. Whether Holbrook had good cause attributable to the employer to refuse reassignment to two primarily clerical positions after elimination of her assistant curator position.
2. Whether her refusal of the reassignment constituted a disqualifying voluntary quit under Minnesota unemployment compensation law.

## Decision

- The Minnesota Court of Appeals reversed the Commissioner’s determination.
- The court held Holbrook did not voluntarily quit without good cause attributable to the employer.
- The court concluded she was eligible for unemployment benefits.

## Legal Principles

- An employee has good cause attributable to the employer to quit (or refuse reassignment) when the employer makes a substantial, adverse change in the nature or level of the work.
- Equivalence in pay or hours does not, by itself, make a new position “suitable” or “equivalent” if responsibilities and skill level are materially downgraded.
- In evaluating good cause, courts may consider the employee’s established duties, qualifications, and the work the employment relationship had become, not merely the employer’s characterization of the new role.
- A contingent possibility of future improvement (e.g., a review that might upgrade the position) does not negate good cause to refuse a present, materially inferior reassignment.

## Conclusion

Because the museum eliminated Holbrook’s professional assistant curator role and offered only primarily clerical work that materially reduced the level and character of her employment, she had good cause attributable to the employer to refuse the reassignment and remained eligible for unemployment compensation.


Holbrook v. Minn. Museum of Art, 405 N.W.2d 537 (Minn. Ct. App. 1987)