Sawyer v. Department of Workforce Services, 345 P.3d 1253

Amy Sawyer, a Jordan School District special-education teacher, received two failing JPAS evaluations; principal required a third evaluation or termination and offered resignation as an option.
Sawyer resigned because she believed she would fail a third evaluation, be terminated, and be unable to obtain future teaching work; she then applied for unemployment benefits.
The Department of Workforce Services (DWS) denied benefits, finding she quit without good cause; an administrative law judge and the Workforce Appeals Board affirmed.
The ALJ and board relied on the view that because Sawyer might have passed a third evaluation, quitting to avoid discharge did not establish good cause.
Sawyer appealed to the Utah Supreme Court, which considered (1) the proper standard of review for DWS good-cause-to-quit determinations and (2) whether DWS applied the correct legal standard to her case.

Issue	Sawyer's Argument	DWS/Jordan SD's Argument	Held
Standard of review for good-cause-to-quit	Review de novo because issue is a reasonableness determination similar to probable cause/search-and-seizure	Deferential review because the question is fact-like and depends on credibility and varied factual contexts	Good-cause-to-quit is a fact-like mixed question; apply deferential review, but review legal standard for correctness
Whether quitting to avoid a possible discharge can be "good cause"	Resignation to avoid likely termination can be objectively reasonable and constitute good cause	Quitting to avoid a possible discharge does not establish good cause if retention was possible	Reversed: ALJ/Board applied wrong legal standard (asking only whether retention was possible). Must assess whether a reasonably prudent person, based on information known, would be justified in quitting (considering likelihood of termination and effect on future employment).

Hurst v. Indus. Comm’n, 723 P.2d 416 (Utah 1986) (adopts reasonable-person standard for good cause to quit)
Smith v. Indus. Comm’n, 714 P.2d 1154 (Utah 1986) (deference to agency on good-cause questions)
Gibson v. Indus. Comm’n, 707 P.2d 675 (Utah 1985) (mixed law-and-fact nature of good-cause issues; review limited if reasonable basis exists)
State v. Pena, 869 P.2d 932 (Utah 1994) (framework for reviewing mixed questions of law and fact)
State v. Levin, 144 P.3d 1096 (Utah 2006) (Levin factors for choosing de novo vs. deferential review)
Manzanares v. Byington (In re Adoption of Baby B.), 308 P.3d 382 (Utah 2012) (categorization of mixed questions as law-like or fact-like)
Carbon County v. Workforce Appeals Board, 308 P.3d 477 (Utah 2013) (similar mixed-question treatment for employment-termination "just cause")
McDowell v. Employment Dep’t, 236 P.3d 722 (Or. 2010) (resignation to avoid potential discharge can constitute good cause; objective reasonable-person inquiry)