Unemployment Law?s List of Non-disqualifying Reasons for Leaving Work is Not Exhaustive

Two employees, Spain and Batey, claim that they left their jobs because ?they found their employers unbearable.??? Spain suffered daily verbal abuse. Batey left her job with a battered women?s shelter after sharply disagreeing with management on how their clients should be treated, among other things. Both were denied unemployment benefits because the Employment Security Department concluded it no longer had the statutory authority to grant benefits to employees who left work for any reason other than those listed as not disqualifying.?? The Washington legislature had recently amended the Unemployment Compensation Act to disqualify applicants who left work ?voluntarily without good cause? except for one of the specific reasons set forth in the statute.? ?The Court rejected the Department?s? interpretation,? and? held? that according to the plain language of the statute the list of specific reasons set forth is not exhaustive. Spain v. Employment Sec. Dept., 185 P.3d 1188 (Wash. 2008) (Chambers, J., Madsen concurred in result only).