Osman v. Division of Employment Security, 332 S.W.3d 890

Osman Osman, a temporary security guard employed by Ace Personnel, was stationed at Broadway Medical for about six months.
Broadway Medical complained about Osman's performance; Broadway requested his removal, and Ace planned to reassign him to a different client with lower pay, fewer hours, and a longer commute.
Osman rejected the new assignment and applied for unemployment benefits; a deputy initially found he left voluntarily with good cause attributable to work or employer.
Ace appealed, presenting evidence of multiple complaints about Osman’s performance; the Appeals Tribunal reversed, finding no good cause to quit based on a 7.8% pay reduction.
The Commission adopted the Tribunal’s ruling by a 2-1 vote; one Commissioner dissented on the view that the combination of reduced pay, hours, and longer commute could be good cause.
On appeal, the court recognized Osman was a temporary employee of a temporary help firm and discussed the appropriate standard for good cause in that context, ultimately affirming the Commission.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Osman has quit with good cause attributable to work or employer?	Osman argues the pay/hours drop and longer commute constitute good cause.	Ace argues the offered position was reasonable and not outside the range of temporary work expectations.	Osman did not prove good cause; the Commission’s decision upholding disqualification was affirmed.
Should the standard for good cause apply differently to temporary employees?	A reasonable temporary employee may quit for changes in assignment; standard should reflect temporary status.	Reasonableness applies but the offered job was not outside what a temporary worker should expect.	Court acknowledges temporary status but ultimately affirms the Commission’s conclusion based on competent evidence.
Did the Commission apply the correct standard in determining good cause for Osman as a temporary employee?	Commission should apply objective standard for temporary employees and consider mobility/assignment changes.	Commission properly weighed the facts and did not require permanence; the offered job was not unreasonable.	Court notes the Commission applied a less onerous standard but upholds the decision on the record evidence.

Belle State Bank v. Indus. Comm'n of Mo., 547 S.W.2d 841 (Mo. App. 1977) (good-faith standard for voluntary quit; objective reasonableness)
Hessler v. Labor & Indus. Relations Comm'n, 851 S.W.2d 516 (Mo. banc 1993) (good cause determined by objective standard of what a reasonable worker would do)
Partee v. Winco Mfg., Inc., 141 S.W.3d 34 (Mo. App. E.D. 2004) (defines good cause as circumstances motivating a reasonable worker)
Sokol v. Labor & Indus. Relations Comm'n of Mo., 946 S.W.2d 20 (Mo. App. W.D. 1997) (burden on claimant to prove good cause for voluntary termination)
Cooper v. Hy-Vee, Inc., 31 S.W.3d 497 (Mo. App. W.D. 2000) (context for evaluating good cause in employment terminations)
K & D Auto Body, Inc. v. Div. of Emp't Sec., 171 S.W.3d 100 (Mo. App. W.D. 2005) (interpretation of unemployment decision standards)
Ross v. Whelan Sec. Co., 195 S.W.3d 559 (Mo. App. S.D. 2006) (limits on agency interpretation when applying law to facts)
Lashea v. Fin-Clair Corp., 30 S.W.3d 237 (Mo. App. E.D. 2000) (reasonableness standard in employment context)
Bordon v. Div. of Emp't Sec., 199 S.W.3d 206 (Mo. App. W.D. 2006) (objective standard for good cause in unemployment decisions)