Karagozian v. USV Optical, Inc.

Summary

The court clarified that a constructive discharge claim requires proof that the employer intentionally created the complained-of work atmosphere, that the atmosphere was so intolerable a reasonable person would have felt compelled to resign, and that the employee actually resigned. It rejected any additional requirement that the employer specifically intended to force the employee to quit, but affirmed dismissal because the complaint did not allege objectively intolerable conditions or establish that the cited regulatory materials and statute made the plaintiff's assigned duties unlawful.