Briefs filed in Gloria A. Hayes, Relator, vs. K-Mart Corporation, Respondent, Commissioner of Employment and Economic Development, Respondent.

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Minnesota Appellate Court Issues in Briefs

Shown here are the statements of the issues presented for review by the appellate courts in the briefs filed for this case. The entire brief set can be found at the State Law Library and other libraries around the state. See Minnesota Appellate Court Briefs Collection for more information.

CASE NAME:  Gloria A. Hayes, Relator, vs. K-Mart Corporation, Respondent, Commissioner of Employment and Economic Development, Respondent.
        Read the opinion in this case at C1-02-2056
        CITATION:  665 N.W.2d 550 (Minn.App. 2003)

Legal Issues in BRIEF AND APPENDIX OF RELATOR:
  • Whether an employee establishes good cause to quit where the employer promises a raise but then stalls on the promise for over a year and also demands increasingly onerous work commitments from the employee to respond to short staffing? Commissioner's representative held: Breach of a promise to pay a raise in the future is not a compelling reason to quit and being asked to cover for absent workers is not good cause to quit.

    Legal Issues in RESPONDENT-COMMISSIONER'S BRIEF AND APPENDIX:

  • Whether the record reasonably supports the commissioner's representative's decision that Relator - who was frustrated with the demands of the job and wanted a pay raise - quit her employment, but without a good reason caused by the employer? The commissioner's representative, Keith E. Goodwin, found in the affirmative. Most apposite statutes: Minn. Stat. § 268.095, subds. 1-3 (2002). Most apposite cases, not to exceed four: Trego v. Hennepin County Family Day Care Association, 409 N.W.2d 23 (Minn. Ct. App. 1987); Potz v. Pipestone Skelgas, 397 N.W.2d 12 (Minn. Ct. App. 1986); Ryks v. Nieuwsma Livestock Equipment, 410 N.W.2d 380 (Minn. Ct. App. 1987); Whitehead v. Moonlight Nursing Care Inc., 529 N.W.2d 350 (Minn. Ct. App. 1995).

    Legal Issues in REPLY BRIEF OF RELATOR:

  • Where an employer promises an employee a raise, the employer confirms this promise repeatedly over the course of a year, the employee works for that period in reliance on the promise, and then the employer reneges, the employee has a good reason to quit.
  • Breach of the promise to pay a raise is a substantial adverse change in employment condition sufficient to amount to a good reason to quit.
  • Job frustration, alone, was not the reason that Hayes quit.
  • Hayes acted as a reasonable person would have when she quit.


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