BARRIGA v ADES/PRECISION
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In this case, Pedro Barriga, an auto detailer at Precision Auto Body, LLC, quit his job due to a dispute with a coworker over the placement of a cooling fan and a perceived favoritism shown by his supervisor towards his coworker. Barriga then applied for unemployment benefits from the Arizona Department of Economic Security (“ADES”), claiming he quit due to an intolerable work situation. The ADES initially denied his benefits, but an Administrative Law Judge (“ALJ”) reversed this decision. Precision Auto Body appealed to the ADES Appellate Services Administration Appeals Board, which reversed the ALJ's decision, finding that the working conditions at Precision did not rise to the level of an intolerable work situation.
Barriga appealed to the Arizona Court of Appeals, which vacated the Appeals Board’s decision, interpreting the factors in Arizona's regulation R6-3-50515(C)(2) as non-exhaustive and remanding the case back to the Appeals Board.
The Supreme Court of the State of Arizona, however, disagreed with the Court of Appeals, vacating its opinion and affirming the Appeals Board’s decision. The court held that while the factors in R6-3-50515(C)(2) meant to determine whether a workplace situation is intolerable are not exhaustive, Barriga failed to present evidence of any unbearable condition to establish an intolerable work situation. A dispute over a cooler placement, while unpleasant, was not intolerable. The court also found that Barriga did not adequately attempt to adjust his grievance before leaving his employment. The court also concluded that Barriga waived his claim that he quit because of a health condition by failing to sufficiently raise this issue at earlier stages of the proceedings.
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