Thompson v. Christiana Care Health System, 25 A.3d 778

Thompson worked for Christiana Care Health System from 2002 to 2008 as an administrative assistant amid a disruptive workplace with co-worker conflicts.
Thompson sought a transfer but was told no transfer was available; she claimed ongoing hostility and a deteriorating environment.
Approximately three days before resigning, Thompson discussed transfer or resignation with a supervisor (Cannatelli); transfer remained unavailable.
Thompson resigned on February 1, 2008 and applied for unemployment benefits on March 2, 2008.
UIAB initially found Thompson eligible for benefits for good cause; Superior Court reversed, holding unhappy work conditions do not constitute good cause and that the record lacked substantial evidence.
On appeal, the Delaware Supreme Court affirms the Superior Court’s reversal, holding no substantial evidence supports UIAB’s good-cause finding and Thompson did not exhaust administrative remedies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Thompson had good cause to quit.	Thompson asserts a chaotic work environment and transfer denial justified quitting.	Thompson’s unhappiness alone does not constitute good cause; no evidence of improper denial of transfer.	No; unhappy environment does not establish good cause.
Whether Thompson exhausted administrative remedies before resigning.	Thompson attempted some remedies and spoke to supervisors; exhaustion occurred.	Thompson failed to exhaust reasonable alternatives, e.g., proper HR channels and timely use of Employee Relations.	No; Thompson failed to exhaust reasonable alternatives before quitting.
Whether substantial evidence supported UIAB's good-cause determination.	Evidence showed ongoing workplace issues affecting Thompson’s ability to work.	Record did not show good cause; other employees could transfer and Thompson was not proven qualified.	No; substantial evidence did not support UIAB's good-cause finding.

O'Neal's Bus Service v. Employment Sec. Comm'n, 269 A.2d 247 (Del. Super. Ct. 1970) (good-cause standard requires reasonable basis for quitting)
Histed v. E.I. du Pont de Nemours & Co., 621 A.2d 340 (Del. 1993) (unemployment standards; causation and reasonableness considerations)
Swann v. Cabinetry Unlimited, 1993 WL 487892 (Del. Super. Ct. 1993) (historical view on required tolerance of working conditions)
Straley v. Advance Staffing, Inc., 984 A.2d 124 (Del. 2009) (appellate review of UIAB credibility and evidence standards)
Duncan v. Unemployment Ins. Appeal Bd., 337 A.2d 308 (Del. 1975) (substantial evidence and legal error standards for UIAB review)