## Facts

- Leo E. Murphy, age 50, worked for Kaiser Aluminum & Chemical Corporation for about 17 years as a brickmason.
- Kaiser eliminated Murphy’s brickmason position due to a workforce reduction but offered continued employment in the pot room at a 5% wage reduction.
- Murphy’s brickmason work was sometimes strenuous, with occasional jackhammer use, limited lifting, and temperatures sometimes around 100°F.
- The pot room work likely required Murphy to spend more than half his time as a carbon setter, standing on a narrow catwalk above vats of molten metal (about 1,100°F to 1,300°F) and using a heavy crowbar to break crust on the metal, while exposed to heat and gases.
- Murphy refused the transfer, citing the extreme heat and gases and describing the job as suited to younger workers, and he left employment.
- A Job Service Center initially granted unemployment benefits; after employer appeal, an appeals examiner found Murphy voluntarily left work without good cause, and the Commissioner adopted that decision.
- The superior court affirmed the agency denial; Murphy appealed.

## Issues

1. Whether Murphy left work voluntarily without good cause, disqualifying him from unemployment benefits under the Washington Employment Security Act.
2. Whether the agency correctly applied the “reasonably prudent person” standard to a transfer involving a major increase in hazard and physical demands plus a wage reduction.
3. Whether Murphy exhausted reasonable alternatives before leaving employment.

## Decision

- The Court of Appeals reversed the superior court and the agency denial of benefits.
- The court held Murphy had good cause to refuse the pot room position and to leave employment.
- The court concluded the agency’s determination that Murphy lacked good cause was erroneous under the governing standard and the administrative record.

## Legal Principles

- Good cause for voluntary unemployment requires: (1) leaving primarily because of a work-connected factor so compelling that a reasonably prudent person would leave, and (2) exhaustion of all reasonable alternatives prior to termination.
- Whether a work-connected factor would cause a reasonably prudent person to leave is a fact-specific inquiry.
- A modest wage reduction may be insufficient alone, but a drastic change in the nature of the work—including materially increased danger, heat exposure, and physical demands—can constitute a substantial deterioration in working conditions supporting good cause.
- Under judicial review of agency action, courts examine the whole record and may reverse where the decision is clearly erroneous or reflects misapplication of the legal standard.

## Conclusion

Murphy’s long-term position was eliminated, and the only offered alternative required substantially more hazardous and physically demanding work in extreme heat with exposure to gases and a wage reduction; under these circumstances, a reasonably prudent person could leave employment, and Murphy was entitled to unemployment benefits.


Murphy v. Emp. Sec. Dep’t, 47 Wash. App. 252, 734 P.2d 924 (Wash. Ct. App. 1987)