## Facts

- Maria Jaime worked for Ed Miniat, Inc. for about 10 years at a Chicago plant near her home.
- In December 1995, the employer relocated its facility about 16 miles away, from Chicago to South Holland, Illinois.
- Jaime did not drive and initially continued working by obtaining rides from a co-worker.
- When that co-worker left the employer, Jaime lacked reliable transportation to the new location, which was less accessible by public transit than the prior site.
- Jaime applied for unemployment benefits on February 11, 1996, and resigned on February 13, 1996, citing lack of transportation caused by the relocation.
- The IDES claims adjudicator denied benefits for voluntary leaving; an IDES referee and the Board of Review affirmed, finding no good cause attributable to the employer.
- On administrative review, the circuit court reversed as against the manifest weight of the evidence; the Director and Board appealed.

## Issues

1. Whether an employer-initiated relocation that materially impairs an employee’s ability to commute can constitute “good cause attributable to the employer” under the Illinois Unemployment Insurance Act.
2. Whether the Board of Review’s determination that Jaime voluntarily left without good cause attributable to the employer was against the manifest weight of the evidence.

## Decision

- The appellate court affirmed the circuit court’s judgment reversing the Board of Review.
- The court held the Board’s finding of a disqualifying voluntary quit without good cause attributable to the employer was against the manifest weight of the evidence.
- Jaime’s resignation was treated as prompted by good cause attributable to the employer, rendering her eligible for unemployment benefits.

## Legal Principles

- A claimant bears the burden to establish eligibility for unemployment benefits, but the Unemployment Insurance Act is liberally construed to favor awarding benefits.
- On administrative review, a Board decision may be reversed if it is against the manifest weight of the evidence, meaning the opposite conclusion is clearly evident or the finding is unreasonable on the record.
- A substantial employer-initiated change in the job’s location or conditions can supply good cause attributable to the employer, even when the separation is formally voluntary.
- Transportation difficulties may be attributable to the employer when they are directly triggered by the employer’s relocation and effectively prevent continued work despite the employee’s willingness to remain employed.

## Conclusion

Because the employer’s relocation materially altered the job’s accessibility and left Jaime without feasible transportation to continue working, the appellate court concluded that her resignation was for good cause attributable to the employer and that the Board’s denial of benefits could not stand under the manifest-weight standard.


Jaime v. Dir., Dep’t of Emp. Sec., 704 N.E.2d 721 (Ill. App. Ct. 1998)