Under Some Circumstances, Officer Who Resigns Can Receive Unemployment Compensation

Michael Meaney was a police officer for the City of Woburn, Massachusetts from September 1992 until May 2003. Meaney left work in order to address heath issues (alcoholism and post traumatic stress disorder (PTSD)) arising from a work-related incident on January 15, 2003. These issues had been negatively impacting Meaney’s marriage, family, and job.

When the Police Chief denied Meaney’s request for a leave of absence to deal with his issues, Meaney resigned. Meaney subsequently filed a request for unemployment compensation. The City rejected the request, contending that Meaney had voluntarily resigned his job, and that only employees who were terminated were entitled to unemployment compensation benefits.

The Appeals Court of Massachusetts upheld Meaney’s request for benefits. The Court found that under Massachusetts law, if a reservation arose for reasons that were “urgent, compelling, and necessitous,” the employee’s separation from work was “involuntary.” The Court held that given all of the pressures on Meaney, coupled with the Chief’s decision not to allow Meaney to take a leave of absence, Meaney’s decision to leave work was equivalent to an involuntary termination.

The City pointed to the fact that Meaney had told his psychologist that he was not bothered by the January 15, 2003 work-related incident, and that he had no alcohol-related problems. The Court rejected the City’s arguments, finding that the unemployment compensation hearings officer “could reasonably have found that Meaney had lied to the psychologist out of economic necessity. At the unemployment compensation hearing, Meaney corroborated his oral testimony about the effects of and treatment for his alcoholism and PTSD with three ‘To Whom It May Concern’ notes from health care professionals and one from the medical records department of a hospital. Based on this documentation and Meaney’s testimony, the hearings officer could properly have determined that Meaney was telling the truth about his reasons for leaving his job.”

City of Woburn v. Commissioner of the Department of Employment and Training, 837 N.E.2d 729 (Mass.App. 2005).

This article appears in the January 2006 issue