Silent Type, Inc. v. Bd. of Review, No. 25-2-2096 (App. Div., November 5, 2008) – In this matter, the court held that an employer’s unilateral change in an employee’s work schedule constituted good cause for claimant to resign, and would not preclude receipt of unemployment benefits, where the schedule change prevented the employee from picking up her daughter from daycare by the closing time.

This case draws the important distinction between those situations where an employer’s change in an employee’s work schedule directly affects established child care arrangements from cases where such child care problems/conflicts arose through no action on the part of the employer. In the latter case, unemployment benefits will not be awarded.