## Facts

- Tenner Jones worked as a cook for Marian Hill.
- When Jones accepted the job, she told her supervisor she could work only from 9:00 a.m. to 3:00 p.m. because of family responsibilities.
- After about three months, the employer told Jones she would have to work until 6:00 p.m.
- Jones objected, but the employer told her that if she would not work the new schedule, a replacement would be hired.
- Jones initially said she would accept the new hours, but the next day she told her supervisor she could not work until 6:00 p.m. because she had four children to care for.
- Jones continued working only until a replacement for her position was found.
- Jones applied for unemployment-compensation benefits.
- A deputy denied benefits, and the Review Board affirmed, concluding Jones voluntarily left employment without good cause connected with the work.
- Jones appealed to the Indiana Court of Appeals.

## Issues

1. Whether an employee leaves employment “voluntarily without good cause in connection with the work” when the employer materially changes an agreed work schedule and the employee cannot continue under the new hours due to previously disclosed family responsibilities.
2. Whether the employee’s brief continuation of work while the employer found a replacement shows an election to accept the new schedule that defeats a claim of good cause.

## Decision

- The Indiana Court of Appeals reversed the Review Board’s denial of benefits.
- The court held that Jones had good cause connected with the work to leave because the employer imposed a substantial change to a key term of employment—her agreed hours.
- The court concluded that Jones’s short-term continuation of work while a replacement was located did not convert the separation into a voluntary quit without good cause.

## Legal Principles

- “Good cause in connection with the work” can exist when an employer unilaterally and materially changes a basic term of employment, such as hours of work.
- Where an employee accepts a job with an express limitation on availability that the employer accepts, that limitation becomes part of the employment arrangement for purposes of evaluating good cause.
- A claimant is not disqualified from unemployment benefits merely because she initially attempts to continue working after an announced change; prompt objection and a separation tied to the changed condition may still be for good cause.
- In reviewing unemployment decisions, courts defer to administrative factfinding when supported by evidence but may reverse when the facts do not support the legal conclusion that the claimant left work voluntarily without good cause.

## Conclusion

Jones accepted employment only on the condition that she work 9:00 a.m. to 3:00 p.m., and the employer later required her to work until 6:00 p.m. under threat of replacement. Because this was a material change to an agreed condition of work and Jones promptly stated she could not comply due to her childcare obligations, the court held she left with good cause connected with the work; her temporary continuation until a replacement was found did not defeat eligibility, so the Review Board’s denial of benefits was reversed.


Jones v. Review Board of the Indiana Employment Security Division, 399 N.E.2d 844 (1980)