(internal citations omitted). The classic "follow-the-spouse" scenario involves an employee who resided with his spouse, who then quits his job to follow a relocating spouse. Relying on past precedent, the Court explained:
Where a claimant terminates employment to join a relocating spouse, the claimant must demonstrate an economic hardship in maintaining two residences or that the move has posed an insurmountable commuting problem. The claimant must also show that her resignation was the direct result of her spouse's relocation, i.e., the necessity to relocate must be caused by circumstances beyond the control of the claimant's spouse and not by personal preference, and the decision to relocate must be reasonable and be made in good faith. These principles reflect the General Assembly's intent to permit the obligation of joining one's spouse, under the proper circumstances, to constitute cause of a necessitous and compelling nature to leave one's employment. The desire to maintain the family unit is not by itself sufficient cause to terminate one's employment and receive benefits.(internal citations omitted). So, why was this case different?
In Pa. Gaming Control Bd., the spouse relocated before the couple got married. Does that matter? Per the Court's opinion, not really - it's still the same test. Here, the relocation was based in part on personal preference, but also the "economic hardship" of maintaining two residences and the "insurmountable commuting distance" (in this case, Pennsylvania to Louisiana). Accordingly, the claimant was eligible for benefits.