Kash Snyder v. Unemployment Compensation Board of Review

Summary

The Pennsylvania Commonwealth Court affirmed the Unemployment Compensation Board of Review’s denial of benefits to Kash Snyder under section 402(b) of the Pennsylvania Unemployment Compensation Law. The court held that Snyder voluntarily quit his employment after rejecting an employer-proposed part-time accommodation to pursue elected office, and that he failed to establish a necessitous and compelling reason for leaving. The court also upheld the denial of his request for a remand or reconsideration based on unspecified new evidence.

Holdings

1. Snyder voluntarily quit his employment; the employer's instruction that he go home while it considered his request did not possess the immediacy or finality required for a discharge.
2. Snyder failed to establish a necessitous and compelling reason for quitting because the reduced part-time position was an accommodation to his own request to work part time, and his dissatisfaction with the position's earnings and commission opportunities did not create real and substantial pressure to quit.
3. The UCBR properly denied Snyder's request because he failed to specify the nature of the allegedly unavailable evidence, what testimony was false, or how the proposed evidence related to his entitlement to unemployment compensation.

Questions Presented

1. Whether Snyder voluntarily quit his employment or was discharged when the employer sent him home after he requested reduced hours.
2. Whether Snyder established a necessitous and compelling reason for voluntarily leaving employment based on the reduced earnings and benefits associated with the employer's proposed part-time accommodation.
3. Whether the UCBR abused its discretion by denying Snyder's request for an additional hearing or reconsideration to present allegedly newly available evidence.

Disposition

affirmed