Calvert v. State, Department of Labor & Workforce Development, Employment Security Division, 251 P.3d 990

Calvert quit her job at Snug Harbor Seafoods citing transportation difficulties and workplace conflicts; the claim center denied benefits for quitting without good cause.
A Hearing Officer found transportation issues precipitated the quit but held Calvert failed to exhaust reasonable alternatives to quitting.
The Commissioner affirmed; the superior court upheld the decisions; Calvert appeals seeking reclassification of benefits and a merits review.
Calvert testified about a ten-mile bike commute, unreliable shift notices, CARTS scheduling, a broken bike, and safety concerns at work.
The court conducted an independent review applying four standards of review and ultimately affirmed the denial of benefits.
Key issues include whether Calvert left suitable work for good cause and whether transportation and workplace hostility constituted good cause requiring exhaustion of alternatives.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Calvert's job suitable for the quit analysis?	Calvert argues the hearing neglected suitability analysis.	Calvert contends suitability was impliedly considered and supportable.	Yes; the court held Calvert's work was suitable, and suitability was implicitly addressed.
Did Calvert have good cause to quit based on transportation problems?	Calvert claims transportation issues provided a compelling reason to quit.	Department argued transportation alone did not show exhaustion of reasonable alternatives.	Calvert had a compelling reason but failed to exhaust reasonable alternatives.
Did Calvert's workplace hostility provide good cause to quit?	Calvert asserts hostility and safety concerns were grounds to leave.	Hostility did not rise to health/safety risk and was not the precipitating event.	No; hostility did not constitute good cause for quitting suitable work.
Was Calvert required to exhaust all reasonable alternatives before quitting?	Calvert contends the alternatives were not realistically viable or known to her.	Employer could have accommodated with adjustments; Calvert did not pursue them.	No; Calvert did not exhaust reasonable alternatives before quitting.
Did the Department adequately inform Calvert about eligibility requirements?	Calvert contends the Department failed to properly inform about eligibility.	Informational materials and notices were publicly available and provided.	No; information provided was adequate and publicly accessible.

Tesoro Alaska Petroleum Co. v. Kenai Pipe Line Co., 746 P.2d 896 (Alaska 1987) (standard for substantial evidence in reviewing factual determinations)
Handley v. State, Dep't of Revenue, 838 P.2d 1231 (Alaska 1992) (established framework for reviewing administrative decisions)
Smith v. Sampson, 816 P.2d 902 (Alaska 1991) (substantial evidence review and administrative decisions)
Risch v. State, 879 P.2d 358 (Alaska 1994) (continued application of substantial evidence standard)
Wescott v. State, Dep't of Labor, 996 P.2d 723 (Alaska 2000) (interpreting good cause and suitability in unemployment claims)
AT&T Alascom v. Orchitt, 161 P.3d 1232 (Alaska 2007) (bias and due process considerations in administrative appeals)
Wagner v. Stuckagain Heights, 926 P.2d 456 (Alaska 1996) (hearsay and administrative hearing considerations)
Button v. Haines Borough, 208 P.3d 194 (Alaska 2009) (administrative proceedings and substantial evidence review)
Ferrell v. Baxter, 484 P.2d 250 (Alaska 1971) (presumption of knowledge of the law and due process principles)