J.M. D'Annunzio v. UCBR, 161 C.D. 2017

Jenna M. D’Annunzio worked ~16 years as a screening supervisor for Delaware County Child and Youth Services and signed an Oath of Confidentiality prohibiting disclosure of case information.
She learned two friends of her boyfriend were under investigation for sexual assault of their children and told her boyfriend (in confidence) because she feared they might be brought to her home and endanger her 11‑year‑old daughter.
Employer investigated, terminated her for violating its confidentiality policy, and the Service Center denied unemployment compensation under Section 402(e) for willful misconduct.
The Referee and then the Unemployment Compensation Board of Review found she intentionally divulged confidential information, had no good cause (reasonable alternatives existed), and denied benefits; this appeal followed to the Commonwealth Court.
Claimant conceded the policy existed and was reasonable but argued her disclosure was not willful misconduct because it resulted from panic to protect her child and thus was justified under Grieb.

Issue	D’Annunzio’s Argument	Employer/Board’s Argument	Held
Whether disclosure of confidential case information constituted willful misconduct under Section 402(e)	Disclosure was not willful misconduct — it was a panicked, non‑deliberate act to protect her child (relying on Grieb)	She intentionally and knowingly told her boyfriend confidential information in violation of a reasonable, known policy	Held: Willful misconduct. She admitted deliberate disclosure despite knowing the confidentiality requirement.
Whether claimant had "good cause" to violate the confidentiality rule	She had good cause because disclosure was necessary to protect her child’s safety	A reasonable alternative existed (tell boyfriend not to bring those friends) so no good cause excused deliberate violation	Held: No good cause. Reasonable alternatives meant the violation was unjustified and remains willful misconduct.

Navickas v. Unemployment Compensation Board of Review, 787 A.2d 284 (Pa. 2001) (defines willful misconduct elements)
Grieb v. Unemployment Compensation Board of Review, 827 A.2d 422 (Pa. 2003) (totality of circumstances can negate willfulness for inadvertent conduct)
Arbster v. Unemployment Compensation Board of Review, 690 A.2d 805 (Pa. Cmwlth. 1997) (good‑cause requires absence of reasonable alternatives)
McKeesport Hospital v. Unemployment Compensation Board of Review, 625 A.2d 112 (Pa. Cmwlth. 1993) (employee may show good cause after an intentional rule violation)