Campbell v. State of Washington Employment Security Department

Summary

The Washington Supreme Court affirmed the denial of unemployment benefits to Robert Campbell after he resigned from his teaching position seven months before relocating to Finland with his wife, who had received a Fulbright grant. The court held that Campbell did not remain employed as long as was reasonable before the move, as required by Washington’s “quit to follow” provision, RCW 50.20.050(2)(b)(iii). The court did not decide whether the Fulbright grant qualified as employment.

Holdings

1. Campbell's resignation seven months before the planned relocation was not objectively reasonable under RCW 50.20.050(2)(b)(iii), so he failed to satisfy the quit-to-follow provision and was disqualified from unemployment benefits on that basis.
2. The reasonableness inquiry is not subjective; it asks whether the claimant's actions were objectively reasonable under the particular facts.
3. The agency did not err in denying Campbell benefits, and its decision was not clearly erroneous or otherwise invalid under the applicable standards of review.

Questions Presented

1. Whether Campbell remained employed as long as was reasonable before relocating for his spouse's employment or qualifying activity under RCW 50.20.050(2)(b)(iii).
2. What standard governs the determination of whether a claimant remained employed as long as was reasonable under the quit-to-follow provision.
3. Whether the agency's denial of unemployment benefits was supported under the Administrative Procedure Act.

Disposition

affirmed