C.L. Pratt v. UCBR, C.L. Pratt v. UCBR

Claimant Clair L. Platt worked for Laurel Arts from 2002 to April 2016 as a maintenance supervisor.
On April 6, 2016, the executive director suspended Platt for refusing to sign two counseling reports he believed were false; he was to return April 13 but did not.
Platt did not formally resign but chose not to return because he feared further false allegations and reputational harm; he sought, without success, to have the board of directors intervene during his suspension.
The local job center found Platt ineligible for unemployment benefits under Section 402(b) (voluntary leaving without necessitous and compelling cause).
A referee and the Unemployment Compensation Board of Review credited Platt’s testimony but concluded his fear was speculative and he failed to make reasonable efforts to preserve employment, so he was ineligible for benefits.
The Commonwealth Court affirmed, holding speculative fears and failure to notify employer of intent not to return do not meet the necessitous and compelling standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Claimant voluntarily left for necessitous and compelling cause under Section 402(b)	Platt: Executive director’s false accusations and hostile conduct created a hostile work environment constituting constructive discharge and necessitous cause to quit	Board/Employer: Platt voluntarily quit based on speculative fear of future accusations and did not preserve employment; no constructive discharge shown	Held: No. Platt’s fears were speculative, he did not notify employer he would not return or make adequate efforts to preserve employment; ineligible under §402(b).
Whether constructive discharge occurred	Platt: Employer’s conduct amounted to discharge in effect	Board: No showing that employer’s actions produced immediacy or finality of a firing	Held: No constructive discharge; no evidence he resigned to avoid imminent discharge.
Whether claimant made reasonable efforts to preserve employment	Platt: He contacted board members during suspension seeking relief	Board: Efforts were insufficient; he did not await or exhaust employer procedures or inform employer he would not return	Held: Efforts inadequate; failure to preserve employment supports ineligibility.

Dopson v. Unemployment Compensation Board of Review, 983 A.2d 1282 (Pa. Cmwlth.) (necessitous and compelling cause standard for voluntary leaving)
Mathis v. Unemployment Compensation Board of Review, 64 A.3d 293 (Pa. Cmwlth.) (must show real and substantial pressure and reasonable efforts to preserve employment)
Green Tree School v. Unemployment Compensation Board of Review, 982 A.2d 573 (Pa. Cmwlth.) (speculative fears insufficient to establish necessitous and compelling cause)
Salamak v. Unemployment Compensation Board of Review, 497 A.2d 951 (Pa. Cmwlth.) (board’s credibility findings are conclusive on appeal)