Generally, an employee who voluntarily terminates employment is not eligible for unemployment compensation.  However, this is not the case where an employee quits due to "good cause attributable to the employer."

In Kierstead v. LIRC, 2011AP938 (April 3, 2012), the Court of Appeals clarified the law regarding what constitues such "good cause."  In that case, the employee quit because he refused to sign a form acknowledging receipt of a disciplinary warning.  He was told by his supervisor he would have to sign the form, or he would be fired.

The employee quit.  He filed for unemployment compensation benefits.  He testified that he had not been told that signing the form would constitute an admission of the facts stated in the warning or of its appropriateness, and the form contained no language indicating that was the case.  He testified he quit because he thought his supervisor was "bluffing" when he told the employee he would be fired if he refused to sign.

The Court of Appeals held that the employee under the circumstances had quit without good cause attributable to the employer.  The court stated that a requirement that an employee sign acknowledging receipt of a warning or complaint in and of itself would not create such good cause in the event the employee quit due to such requirement.  However, the court further indicated that if an employee quits because he is required to sign and that act constitutes an admission of the accuracy or propriety of the warning, the employee would be deemed to have quit for good cause attributable to the employer.