MacGregor v. Unemployment Insurance Appeals Board

On January 1, 1980, Patricia MacGregor (plaintiff) began a six-month pregnancy leave of absence from her job as a waitress at a Ramada Inn in Santa Clara, California. MacGregor lived with Dick Bailey, the father of her child. While MacGregor was on leave, she and Bailey decided to move to New York to help care for Bailey’s elderly father, who was undergoing treatment for several serious medical issues. MacGregor notified her employer that she would not return to work, and she, Bailey, and their daughter moved in with Bailey’s father in New York. When MacGregor was unable to find employment there, she applied for unemployment-compensation benefits in California. MacGregor’s claim was denied, and the Unemployment Insurance Appeals Board (board) (defendant) affirmed, finding that MacGregor had quit voluntarily without good cause and was, therefore, ineligible for benefits. Although preservation of MacGregor’s family unit would have constituted good cause for her resignation, the board found that there was no family unit to be preserved because MacGregor and Bailey were not married and had no definite plans to marry in the future. MacGregor appealed, and the superior court reversed, finding that MacGregor and Bailey had lived together for three years, that they had established a family unit with their child, and that MacGregor had left her employment to preserve that family unit and was, therefore, eligible for benefits. The board appealed.