The District of Columbia allows a worker who quits her job voluntarily to collect unemployment compensation if she quits with "good cause connected to the work." Chapter 7 of the D.C. municipal regulations, provides a nonexhaustive list of reasons considered "good cause," including racial or sexual discrimination or harassment, failure to pay the employee, and unsafe working conditions.
Maria Alvarado, a laundry manager at Imperial Valet Services, quit her job because of repeated verbal abuse, alleging that her employer called her "stupid," "a piece of crap," and "a jerk," as well as yelling profanities at her, sometimes in front of her daughter or other employees.
An administrative law judge determined that she had quit for good cause and was entitled to unemployment benefits, and her employer appealed. The D.C. Court of Appeals heard the case, noting that it was the first time the question of whether verbal abuse constituted good cause had come before the court.
How should a court determine whether good cause exists? Is an employer ever justified in yelling at an employee, calling her a name, or using profanity?