Warkentin v. Employment Department, 261 P.3d 72

Warkentin worked as a patient coordinator for Northwest Cardiologists at the St. Vincent's office, performing clerical, scheduling, transcription, and bookkeeping/insurance billing for one physician.
The St. Vincent's office had four physicians and staff; Hillsboro office had similar structure but fewer tasks performed by different employees.
Claimant repeatedly requested additional support staff due to heavy workload; requests were denied as unaffordable, with a part-time helper eventually hired but workload remained onerous.
In May 2010 the part-time helper quit, leaving claimant solely responsible again; she began diverting calls to Hillsboro to manage backlog, which Hillsboro later rejected.
Claimant suffered work-related stress, depression, migraines, insomnia, and had a prior suicide attempt in 2005; she testified she could not request time off due to understaffing and limited sick leave.
In June 2010, after a move to a larger facility and additions to staff for a new provider, claimant quit on June 8, 2010 following a confrontation about overtime; four new employees were hired afterwards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the board's finding of no good cause supported by substantial evidence?	Warkentin argues record supports board findings and requires remand.	Employer argues board properly found lack of good cause given alternatives were available.	Reversed and remanded
Did the board adequately explain how its findings support the legal conclusion?	Warkentin contends board failed to show reasoning linking findings to conclusions.	Employer contends findings reasonably supported its decision.	Remand for adequate reasoning
Were the three stated alternatives to quitting properly supported by substantial evidence?	Warkentin contends alternatives (continue working with backlog, leave for treatment, seek other employment) were not supported by evidence or feasible.	Employer asserts board permissibly found reasonable alternatives.	Not sustained; remand
Did the board misinterpret the definition of 'good cause' under ORS 657.176(2)(c) and OAR 471-030-0038(4)?	Warkentin argues the rule does not require seeking other employment before quitting and can support quitting for grave conditions.	Employer argues the rule allows quitting with grave cause but required contemplation of alternatives.	Reversed and remanded

McDowell v. Employment Dept., 348 Or. 605 (Or. 2010) (tests whether a situation is grave enough to leave with no reasonable alternative)
Hertel v. Employment Division, 80 Or. App. 784 (Or. App. 1986) (no requirement to seek other employment before quitting to show good cause)
Blivens v. Employment Division, 55 Or. App. 665 (Or. App. 1982) (same principle re: good cause and quitting)
Peterson v. Employment Div., 39 Or. App. 49 (Or. App. 1979) (evidence sufficiency for employment decisions)
Hill v. Employment Dept., 238 Or. App. 330 (Or. App. 2010) (reversed where board lacked substantial evidence for reasonable alternatives)
Drew v. PSRB, 322 Or. 491 (Or. 1996) (requires agency to connect facts to decisional standards)
City of Roseburg v. Roseburg City Firefighters, 292 Or. 266 (Or. 1981) (reasoning basis required to support agency conclusions)