Santa Williamson, Relator,

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A24-1958

Santa Williamson,
Relator,

vs.

Chisholm HRA,
Respondent,

Department of Employment and Economic Development,
Respondent.

Filed October 20, 2025
Affirmed
Bratvold, Judge

Department of Employment and Economic Development

Santa Williamson, Chisholm, Minnesota (pro se relator)

Chisholm HRA, Chisholm, Minnesota (respondent employer)

Keri A. Phillips, Minnesota Department of Employment and Economic Development, St.
Paul, Minnesota (for respondent department)

Considered and decided by Bjorkman, Presiding Judge; Frisch, Chief Judge; and
Bratvold, Judge.
NONPRECEDENTIAL OPINION
BRATVOLD, Judge
Relator challenges an unemployment-law judge’s (ULJ’s) decision that she was
ineligible for unemployment benefits because she voluntarily quit her employment. Relator
2
challenges the ULJ’s credibility determinations rejecting her testimony, contending that
the ULJ’s determinations were “one-sided.” She also argues that she had good reason to
quit caused by her employer because of an “unreasonable workload” and “medical
conditions exacerbated by work conditions.” Because we discern no error in, and therefore
defer to, the ULJ’s credibility determinations, and because relator did not have a good
reason to quit caused by her employer and did not quit because of medical necessity , we
affirm.
FACTS
Following an evidentiary hearing, the ULJ submitted a written decision that
included factual findings. This opinion summarizes the ULJ’s decision and factual findings
as well as the relevant evidence.
Relator Santa Williamson worked as an administrative assistant for respondent
Housing & Redevelopment Authority of Chisholm (HRA) from September 30, 2019, to
April 19, 2024. She usually worked 24 hours each week and earned $24.50 per hour.
Williamson’s position changed in November 2023. Williamson testified that HRA was “in
the middle of an audit,” its executive direct or suddenly resigned, and a maintenance
employee was out “due to an injury.”
As a result, Williamson took on “some of the executive director duties,” in addition
to performing her administrative-assistant duties, “until a new director was hired.”
Williamson “normally” responded to tenant calls “during daytime hours as the
administrative assistant.” Starting in December 2023, Williamson “was on-call during the
weekends to respond to tenants.” Williamson’s hours increased to 32 to 35 hours a week,
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and she continued to earn $24.50 per hour. Williamson was paid an additional $500 per
week, plus overtime, “which was 1.5 times her hourly rate of pay,” if she “had to physically
go in to address an issue.”
The ULJ found that (1) the “calls felt overwhelming to Williamson because she
struggled to get her regular job duties done in addition to the executive director duties” and
(2) Williamson “felt harassed by her perception of the [tenants’] social media posts and
tenants addressing her when she was out in public.” The ULJ also found that Williamson
was diagnosed with high blood pressure and anxiety. Williamson told her supervisor that
she was “stressed by the job duties and had high blood pressure,” but “Williamson never
told” her supervisor “that she was diagnosed with anxiety.” And the ULJ found that
“Williamson requested to take time off, including sometimes leaving early, on days she
felt overwhelmed.” Williamson’s supervisor “told Williamson she could take off whatever
time she needed.” Williamson did not request other accommodations.
In January 2024, HRA informed Williamson that the city administrator “was
available to help Williamson complete tasks.” But Williamson “never enlisted the city
administrator’s help because she chose not to take time to train her.” The ULJ added that
Williamson “felt that she did not have time to train the city administrator or provide
instructions for how to do things.” HRA also told Williamson that “the HRA housekeeper
was available to perform filing or other basic administrative duties.” Williamson asked the
housekeeper “to come in and file work orders twice.”
HRA hired a new executive director at the end of March 2024 with a scheduled start
date of April 22. The ULJ found that “Williamson knew” that HRA had “hired a new
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executive director,” but she “assumed her stress level would not improve.” On April 1,
Williamson notified HRA in writing that she would quit effective April 19, 2024. When
Williamson gave notice, she also informed HRA “that she was diagnosed with mental
health impairment due to stress.”
Williamson applied for unemployment benefits on April 22, 2024. On May 13,
respondent Minnesota Department of Employment and Economic Development (DEED)
issued a determination of ineligibility for unemployment benefits. Williamson appealed the
determination of ineligibility. At the evidentiary hearing, the ULJ heard testimony from
Williamson and her supervisor. DEED submitted exhibits.1
Following the hearing, the ULJ affirmed DEED’s denial of unemployment benefits
in a written decision. First, the ULJ made credibility determinations, finding “the most
likely sequence of events” based on DEED’s exhibits and “primarily” the supervisor’s
testimony, which it found “credible because it was logical, based on first-hand knowledge,
and supported in part by Williamson’s testimony.” The ULJ gave Williamson’s testimony
“less weight” than other evidence because her testimony “went to emotion rather than fact
and [was] at times not logical.”
Second, the ULJ determined that “there were no conditions significantly adverse
enough to compel an average, reasonable worker to quit” and that, therefore, “Williamson
did not quit due to a good reason caused by the employer.” Third, the ULJ considered and

1 DEED’s exhibits included DEED’s determination of ineligibility, Williamson’s appeal,
and both Williamson’s and her supervisor’s responses to DEED’s request for more
information.
5
rejected the exception to ineligibility that applies when “the applicant quit the employment
because the applicant’s serious illness or injury made it medically necessary that the
applicant quit,” citing Minn. Stat. § 268.095, subd. 1(7) (2024). Because HRA
accommodated Williamson’s request to leave early and take time off, and because
Williamson “never requested any other accommodations” and did not tell HRA about her
anxiety diagnosis until after she gave notice, the ULJ determined that this exception did
not apply.
Williamson filed a request for reconsideration. In a written decision, the ULJ
determined that Williamson did not provide any additional information or arguments that
required “changing the decision or ordering another hearing” and affirmed the previous
decision.
Williamson seeks review by writ of certiorari.
DECISION
Upon review, the court of appeals “may affirm the decision” of the ULJ “or remand
the case for further proceedings; or it may reverse or modify the decision” if this court
determines that “the substantial rights” of the relator “may have been prejudiced because
the findings, inferences, conclusion, or decision” are “(1) in violation of constitutional
provisions; (2) in excess of the statutory authority or jurisdiction of the department;
(3) made upon unlawful procedure; (4) affected by other error of law; (5) unsupported by
substantial evidence in view of the hearing record as submitted; or (6) arbitrary or
capricious.” Minn. Stat. § 268.105, subd. 7(d) (2024). This court views “the ULJ’s factual
findings in the light most favorable to the decision, giving deference to the credibility
6
determinations made by the ULJ,” and “will not disturb the ULJ ’s factual findings when
the evidence substantially sustains them.” Ward v. Delta Airlines, 973 N.W.2d 649, 651
(Minn. App. 2022).
In general, an individual may not receive unemployment benefits after quitting
employment. Minn. Stat. § 268.095, subd. 1 (2024). There are, however, ten exceptions to
this general rule. Id. Williamson asserted the good-reason exception and the
medical-necessity exception. Under the good -reason exception, an applicant may receive
unemployment benefits if “the applicant quit the employment because of a good reason
caused by the employer.” Id., subd. 1(1). Under the medical-necessity exception, an
applicant may receive unemployment benefits if they quit “because the applicant’s serious
illness or injury made it medically necessary that the applicant quit.” Id., subd. 1(7).
On appeal, Williamson acknowledges that she voluntarily quit her job but argues
that DEED erred when it determined that she was ineligible for unemployment benefits.
Williamson asks us to reverse because the ULJ’s “decision did not adequately consider the
cumulative effect of unreasonable job demands, medical conditions, and unsupported
expectations in a hostile and stressful work environment.”
Because it is undisputed that Williamson voluntarily quit her job, the sole issue on
appeal is whether one of the two exceptions asserted by Williamson applies. See Rootes v.
Wal-Mart Assocs., Inc., 669 N.W.2d 416, 418 (Minn. App. 2003) (“Because it is
undisputed [employee] voluntarily quit her job, the dispositive issue is whether [employee]
quit for good reason caused by [her employer].”). “Whether an employee had good cause
7
to quit is a question of law, which we review de novo.” Ward, 973 N.W.2d at 652 (quotation
omitted).
Williamson raises three main arguments on appeal, which we address in turn. 2
I. Williamson is not entitled to relief based on the ULJ’s credibility
determinations.

Williamson argues that the ULJ made “[o]ne-[s]ided” credibility findings by
dismissing her testimony as “‘emotional’ and not based on ‘objective’ conditions” and
points out that the ULJ acknowledged that her testimony was consistent and that she was
not disciplined for her performance at work. Appellate courts defer to a ULJ’s credibility
determinations and “will not disturb the ULJ’s factual findings when the evidence
substantially sustains them.” Id. at 651.
The ULJ gave Williamson’s testimony “less weight” but did not give her testimony
no weight. The ULJ stated that Williamson’s testimony “went to emotion rather than fact.”
The ULJ commented on the “emotional impact” of tenants’ social-media posts and
in-person comments from tenants , but disagreed with Williamson that this amounted to
harassment, determining that the tenant responses were not objectively “offensive or
hostile work conditions.” On appeal, Williamson does not challenge the ULJ’s findings on
workplace harassment.

2 Williamson’s letter brief asserts five arguments: (1) her unreasonable workload was good
cause to quit; (2) her medical conditions were exacerbated by her work conditions;
(3) support was not realistically available to her; (4) the hiring of a new executive director
did not change her circumstances; and (5) the department’s credibility findings were
one-sided. We adjust and reorder Williamson’s arguments for clarity and ease of
discussion.
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The ULJ also found that Williamson lacked credibility when she asserted reasons
to reject HRA’s efforts to adjust her workload. The ULJ rejected as illogical Williamson’s
testimony that even if she had “train[ed] the city administrator how to perform some of the
job duties it would not improve Williamson’s situation.” The ULJ also rejected as illogical
Williamson’s testimony that “an executive director taking back duties that she would no
longer have to perform would not improve things for Williamson.” We discern no error in
the district court’s credibility findings.
Because substantial evidence supports the ULJ’s factual findings, and because we
defer to the ULJ’s credibility determinations, Williamson is not entitled to relief based on
this argument.
II. The ULJ did not err when it determined that Williamson did not have a good
reason to quit caused by her employer.

Williamson argues that the ULJ erred by determining that she did not have a good
reason to quit caused by her employer under Minn. Stat. § 268.095, subd. 1(1). DEED
urges us to affirm. “A good reason caused by the employer for quitting is a reason” that is
“directly related to the employment and for which the employer is responsible” that is
“adverse to the worker” and “would compel an average, reasonable worker to quit and
become unemployed rather than remaining in the employment.” Minn. Stat. § 268.095,
subd. 3(a) (2024).
The ULJ credited Williamson’s testimony that she was “dissatisfied with her
perception of the working conditions.” The ULJ reasoned, however, that Williamson’s
subjective view of work conditions did not establish the good-reason exception. The ULJ’s
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reasoning is supported by caselaw. When determining whether work conditions would
“compel an average, reasonable worker to quit,” this court applies an objective standard
and considers the conduct of an “average man or woman, and not . . . the supersensitive.”
Werner v. Med. Pros. LLC, 782 N.W.2d 840, 843 (Minn. App. 2010) (quotations omitted),
rev. denied (Minn. Aug. 10, 2010). In Portz v. Pipestone Skelgas, this court held that the
“phrase ‘good cause attributable to the employer’ does not encompass situations . . . where
the employee is simply frustrated or dissatisfied with his working conditions.” 397 N.W.2d
12, 14 (Minn. App. 1986).
Although Williamson experienced stress and struggled to manage her job
responsibilities, these circumstances alone do not demonstrate that an average, reasonable
worker would feel compelled to quit in the same circumstances. Williamson worked more
hours and took on more duties. But HRA also paid Williamson a stipend, her hourly rate,
and overtime when appropriate. And HRA offered Williamson additional support for
completing her duties, which Williamson mostly declined. Williamson quit when a new
executive director was about to start, and her claim that her duties would not change as a
result was not logical.
Williamson argues on appeal that HRA’s offers of additional support did not solve
the workload problem because “the administrator required training that [she] did not have
the capacity to provide while also maintaining [her] own duties” and the “housekeeper was
not equipped to handle administrative responsibilities.” As for the new executive director,
Williamson contends that she “had no reasonable assurance that conditions would
improve” because she was “expected to train this new person without any relief from [her]
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current duties.” As discussed above, the ULJ rejected Williamson’s testimony as not
credible or logical. We defer to the ULJ’s credibility determination. Ward, 973 N.W.2d at
651.
The ULJ determined “that there were no conditions significantly adverse enough to
compel an average, reasonable worker to quit.” Supreme court caselaw and this court’s
previous decisions support the ULJ’s decision. In Jones v. S J & F Enters. Inc. (FM) , this
court determined that a relator did not have a good reason to quit when she “was given
increased hours” because she was “authorized to receive overtime pay,” the increased
workload was temporary, and “the work was not borne by relator alone.” No. A09-2170,
2010 WL 3396876, at *2 (Minn. App. Aug. 31, 2010).
3
Other cases discuss evidence showing a good reason to quit based on increased
workload. In Porrazzo v. Nabisco, Inc., this court concluded that an employee had “good
cause attributable to the employer” when the employer significantly increased Porrazzo’s
workload and did not fully pay him overtime. 360 N.W.2d 662, 664 (Minn. App. 1985).
And in Zepp v. Arthur Treacher Fish & Chips, Inc., the supreme court concluded that Zepp
had good reason to quit caused by his employer when the employer “more than doubled”
his workload without increasing his pay. 272 N.W.2d 262, 263 (Minn. 1978).
The facts here are distinguishable from Zepp and Porrazzo because Williamson was
compensated for her increased workload through her hourly wages, overtime pay, and a

3 “Nonprecedential opinions . . . are not binding authority” but “may be cited as persuasive
authority.” Minn. R. Civ. App. P. 136.01, subd. 1(c). Jones is persuasive because it
considered facts similar to those here. 2010 WL 3396876, at *2.
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weekly stipend. Williamson’s circumstances align with those considered in Jones. Along
with increased pay, HRA offered Williamson additional support to manage her workload
and hired a new executive director. Williamson lacks logical and evidentiary support for
her claims that the new executive director would not result in a change in Williamson’s
workload. Thus, relevant caselaw supports the ULJ’s determination that a reasonable
person would not be compelled to quit under the circumstances Williamson experienced at
HRA.
III. The ULJ did not err when it determi ned that the medical-necessity exception
did not apply.

Williamson argues that she should receive unemployment benefits because her
medical conditions were “exacerbated by work conditions.” The ULJ addressed the
medical-necessity exception, which allows an applicant to receive unemployment benefits
after quitting when “serious illness or injury made it medically necessary that the applicant
quit.” Minn. Stat. § 268.095, subd. 1(7). The ULJ determined that Williamson failed to
satisfy the exception, which applies only if the “applicant informs the employer of the
medical problem and requests accommodation, and no reasonable accommodation is made
available.” Id.
DEED argues that, because Williamson’s informal letter brief did not refer to the
medical-necessity exception, she forfeited this issue. If an issue is not “adequately briefed
on appeal . . . we decline to review [the] issue[].” Broehm v. Mayo Clinic Rochester,
690 N.W.2d 721, 728 (Minn. 2005); see also Ward v. El Rancho Manana, Inc.,
945 N.W.2d 439, 448 (Minn. App. 2020) (“[P]arties forfeit any issues that they do not
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argue in their brief.”), rev. denied (Minn. Oct. 1, 2020). “While an appellant acting pro se
is usually accorded some leeway in attempting to comply with court rules, [they are] still
not relieved of the burden of, at least, adequately communicating to the court what it is
[they want] accomplished and by whom.” Carpenter v. Woodvale, Inc., 400 N.W.2d 727,
729 (Minn. 1987).
While DEED is correct that Williamson’s letter brief does not directly cite or refer
to the relevant statutory exception, her brief argues that her high blood pressure and anxiety
“were worsened by [her] job duties” and that she told her “supervisor of the stress, need
for time off,” and her feeling that she was overwhelmed. Williamson also argues that her
work conditions exacerbated her medical conditions. We therefore conclude that
Williamson adequately asserted the medical-necessity exception and has not forfeited the
issue on appeal.
As stated above, the medical-necessity exception “only applies if the applicant
informs the employer of the medical problem and requests accommodation.” Minn. Stat.
§ 268.095, subd. 1(7). The ULJ found that Williamson notified HRA about her increased
blood pressure and stress and asked for time off. HRA granted Williamson’s request for
accommodation, and the ULJ found that HRA let Williamson leave work early or “be off
work, as needed when she said she was stressed and experienced high blood pressure.” On
appeal, Williamson does not contest these findings.
Williamson gave no notice of her anxiety or mental-health diagnosis until she gave
notice to quit. The ULJ reasoned that Williamson’s act of “[n]otifying the employer she
was stressed is not the same as telling the employer she was diagnosed with a mental health
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impairment.” Because Williamson did not disclose her anxiety diagnosis to HRA until the
day she quit, it is not part of our analysis.
Williamson argues that her stress and high blood pressure were due to “public
harassment” from residents and “constant availability.” This claim is similar to the one
made in Nash v. Mayo Clinic, in which Nash experienced mental-health issues because of
an increased workload. No. A21-0492, 2021 WL 5441779, at *1 (Minn. App. Nov. 22,
2021).4 This court determined that the medical-necessity exception did not apply because
Nash’s employer granted him a medical leave of absence and “the record [did] not indicate
that he sought any [other] accommodation from his employer prior to quitting.” Id. at *3-4.
Like Nash, Williamson requested an accommodation that her employer granted; for
Williamson, that was time off. Like the employer in Nash, HRA received no other
accommodation request. Therefore, the ULJ correctly determined that the
medical-necessity exception did not apply.
Affirmed.

4 Nash, though nonprecedential, is persuasive because it considered facts similar to those
here. Id. at *1, *3-4.