Garcia v. ICAO, 25CA0119

Rena Garcia worked for King Soopers for sixteen years and resigned after conflicts with her supervisor, alleging a toxic workplace and harassment.
After initially wanting to quit, she agreed to transfer to a new store, but soon after a car accident, she did not return to work and was placed on a leave of absence.
Garcia never returned from her leave, and her employment was officially terminated months later.
She applied for unemployment benefits, which were denied on the grounds that she voluntarily left her job for personal reasons not qualifying for benefits under Colorado law.
Multiple levels of appeal followed: an initial denial was remanded for further fact-finding, but was ultimately affirmed, disqualifying Garcia from benefits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Garcia is entitled to unemployment benefits after resigning	Garcia claims she was forced out by a toxic, harassing work environment and thus quit involuntarily	ICAO argues Garcia voluntarily resigned due to dissatisfaction with supervision, not hazardous work	Garcia disqualified; resignation was voluntary
Whether the work environment was objectively unsatisfactory or hazardous	Garcia alleges harassment, exclusion, and a hostile environment from supervisors and coworkers	ICAO asserts no objective evidence of conditions beyond normal workplace dissatisfaction	No sufficient evidence of objectively hazardous conditions
Whether the supervisor's actions justified resignation and qualification for benefits	Garcia asserts supervision and treatment were unreasonable and motivated by retaliation	ICAO contends supervisory actions were within ordinary expectations and not out of the ordinary	Ordinary supervision does not justify benefits
Whether the hearing officer erred in weighing evidence or made credibility mistakes	Garcia contends hearing officer erred, employer representatives were not truthful	ICAO asserts the hearing officer's factual findings and credibility assessments are entitled to deference	Court will not reweigh evidence or disturb credibility findings

Debalco Enters., Inc. v. Indus. Claim Appeals Off., 32 P.3d 621 (Colo. App. 2001) (unemployment benefits require unemployment through no fault of claimant)
Morris v. City & Cnty. of Denver, 843 P.2d 76 (Colo. App. 1992) (employment separation fault is judged by totality of circumstances)
Rodco Sys. Inc. v. Indus. Claim Appeals Off., 981 P.2d 699 (Colo. App. 1999) (unsatisfactory working conditions under unemployment statute must be objectively hazardous)
Musgrave v. Indus. Claim Appeals Off., 762 P.2d 686 (Colo. App. 1988) (ordinary supervisory practices do not justify resignation for benefits)
Cole v. Indus. Claim Appeals Off., 964 P.2d 617 (Colo. App. 1998) (claimant must show inability to continue work to be eligible for involuntary separation benefits)