Sawyer v. Dep’t of Workforce Servs.

Amy Sawyer was a special education teacher for the Jordan School District. When Sawyer received a failing score for her second Jordan Performance Appraisal System (JPAS) evaluation, Sawyer was informed that she would be required to pass a third JPAS evaluation to keep her job or that she could resign in order to avoid the third evaluation. Concerned that if she were terminated that she would not find future employment as a teacher, Sawyer elected to resign rather than submit to a third JPAS evaluation. The Department of Workforce Services (DWS) denied Sawyer’s application for unemployment benefits based upon its finding that Sawyer quit her job without good cause. An administrative law judge (ALJ) upheld DWS’s decision, and the Workforce Appeals Board affirmed. The Supreme Court reversed, holding (1) good cause to quit is a fact-like mixed question of law and fact reviewed deferentially; but (2) the ALJ and Appeals Board applied an incorrect legal standard to this mixed question. Remanded. View "Sawyer v. Dep’t of Workforce Servs." on Justia Law