Connolly v. Director of the Division of Unemployment Assistance, 460 Mass. 24

Kristen Connolly, a Verizon customer service representative in Lowell, accepted a voluntary separation package offered in 2008 amid a department restructuring.
Verizon did not mention or imply a layoff; Connolly was not compelled to apply and did not believe her job was in jeopardy.
Reasons for accepting the package included dislike of the job, long commute, and potential transfer concerns to another Verizon facility.
No layoffs occurred in Connolly's department after she left Verizon; she applied for unemployment benefits and was initially approved.
Verizon appealed, and the review examiner denied benefits, with the board affirming the denial based on lack of good cause attributable to the employer.
The issue on appeal was whether Connolly’s voluntary departure, despite an employer-initiated workforce reduction context, qualified as involuntary under G. L. c. 151A, § 25(e)(1).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Morillo control whether the leaving was involuntary?	Connolly argues Morillo should apply since Verizon initiated a workforce reduction and took the final step by termination.	Verizon argues State St. and White control; the final act was not a layoff in Connolly's case.	No; Morillo distinguished; board correctly applied State St./White analysis.
Was Connolly's departure attributable to Verizon requiring 'good cause' for unemployment benefits?	Connolly contends there was good cause attributable to the employer.	Verizon contends Connolly left without good cause attributable to the employer because she was not compelled and had no belief of jeopardy.	Connolly did not prove substantial and credible evidence of good cause attributable to Verizon.

Morillo v. Director of the Div. of Employment Sec., 394 Mass. 765 (Mass. 1985) (employer-initiated layoffs or final termination do not necessarily negate good cause)
White v. Director of the Div. of Employment Sec., 382 Mass. 596 (Mass. 1981) (reasonableness of belief in imminent layoff can convert voluntary leaving into involuntary)
State St. Bank & Trust Co. v. Deputy Director of the Div. of Employment & Training, 66 Mass. App. Ct. 1 (Mass. App. Ct. 2006) (incentive-based separation vs. announced layoffs; analysis differs by context)
LeBeau v. Commissioner of the Dep't of Employment & Training, 422 Mass. 533 (Mass. 1996) (liberal interpretation of unemployment statute to aid the unemployed)
Cusack v. Director of the Div. of Employment Sec., 376 Mass. 96 (Mass. 1978) (foundation for intent to provide benefits to unemployed workers)
Leone v. Director of the Div. of Employment Sec., 397 Mass. 728 (Mass. 1986) (good cause requires substantial and credible evidence attributable to employer)
Uvello v. Director of the Div. of Employment Sec., 396 Mass. 812 (Mass. 1986) (remand for factual development on changes in duties and good cause)