Nikol Dowls, Relator v. Select Comfort Retail Corporation, Department of Employment and Economic Development, A16-524

Background

Relator Nikol Dowls worked for Select Comfort from Nov 2012 and was on the order management team; a coworker called her derogatory names in Jan 2015.
Select Comfort investigated in Feb 2015, disciplined the coworker with a written corrective, and issued a corrective to Dowls as well. Employer coached the coworker to be respectful.
Dowls took medical leave Mar–Jun 2015; upon return employer granted most requested accommodations (reduced schedule, relocated cubicle, alternate building shifts, mediator point-of-contact).
Dowls continued to complain of harassment, micromanagement, alleged race-based insults, and that she and another African-American employee had to ask to use the bathroom; she resigned Sept 15, 2015.
DEED initially found Dowls eligible for benefits; Select Comfort appealed. A ULJ found Dowls not credible, concluded harassment ended months before her resignation and that she did not quit for a good reason caused by the employer, and denied benefits. Dowls sought certiorari; the court affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dowls quit for a “good reason caused by the employer” under Minn. Stat. § 268.095	Dowls: sustained, race-based harassment and hostile conditions compelled her to quit despite accommodations	Select Comfort: harassment was investigated and corrected; remaining issues were management style or unsubstantiated; no recent adverse acts compelled quitting	Held: No — ULJ’s factual findings supported that harassment was corrected months before resignation and did not meet the objective good-reason standard
Whether ULJ erred in credibility findings by not explaining rejection of Dowls’ witnesses	Dowls: ULJ failed to state reasons for discrediting other witnesses as required when credibility is outcome-determinative	Select Comfort: ULJ gave specific reasons for rejecting Dowls’ own testimony and relied on contemporaneous employer records; witnesses offered only ancillary support	Held: No — ULJ adequately explained rejection of Dowls’ testimony; other witnesses did not have a significant effect requiring separate credibility findings
Whether co-worker harassment after employer notice could still support benefits	Dowls: ongoing harassment after notice made employer’s corrective measures insufficient	Select Comfort: employer took timely corrective action and follow-ups showed no repeat misconduct	Held: Employer action was timely and effective; harassment was not ongoing, so claim fails
Whether dowls satisfied statutory requirement to complain and give opportunity to correct	Dowls: she repeatedly complained and sought accommodations	Select Comfort: employer received complaints and provided accommodations and corrective action; remaining complaints lacked substantiation	Held: Requirement satisfied; nevertheless, remedial action was effective and the conditions did not compel a reasonable worker to quit

Key Cases Cited

Werner v. Med. Prof’ls LLC, 782 N.W.2d 840 (Minn. App. 2010) (objective standard for whether a reasonable worker would be compelled to quit)
Rowan v. Dream It, Inc., 812 N.W.2d 879 (Minn. App. 2012) (good-cause-to-quit is a legal question reviewed de novo)
Beyer v. Heavy Duty Air, Inc., 393 N.W.2d 380 (Minn. App. 1986) (reason for separation is factual question)
Nichols v. Reliant Eng’g & Mfg., Inc., 720 N.W.2d 590 (Minn. App. 2006) (good-reason conclusion must rest on factual findings supported by substantial evidence)
Skarhus v. Davanni’s Inc., 721 N.W.2d 340 (Minn. App. 2006) (deference to ULJ credibility determinations)
Wetterhahn v. Kimm Co., 430 N.W.2d 4 (Minn. App. 1988) (coworker harassment can be good cause to quit if employer had notice and failed to act)
Ryks v. Nieuwsma Livestock Equip., 410 N.W.2d 380 (Minn. App. 1987) (irreconcilable differences or mere dissatisfaction do not establish good cause to quit)