Karagozian v. USV Optical, Inc.

Summary

The court clarified that a constructive discharge claim requires the employer to have intentionally created the complained-of work atmosphere, but does not require an intent to force the employee to resign. The court nevertheless affirmed dismissal because the complaint did not allege working conditions so difficult or unpleasant that a reasonable person in the employee’s position would have felt compelled to resign. The alleged regulatory materials and staffing statute did not establish that the employer required unlawful conduct or created an intolerable work atmosphere.