A recent Middle District of Pennsylvania case reiterated the "Clowes factors" that federal courts in the Third Circuit (including Pennsylvania) use to determine whether an employer constructively discharged an employee:
(1) threat of discharge;
(2) suggesting or encouraging resignation;
(3) a demotion or reduction of pay or benefits;
(4) involuntary transfer to a less desirable position;
(5) alteration of job responsibilities; and
(6) unsatisfactory job evaluations.Woods v. Salisbury Behavioral Health, Inc., 3:CV-13-539, 2014 WL 957342 (M.D. Pa. Mar. 12, 2014); quoting Clowes v. Allegheny Valley Hosp., 991 F.2d 1159 (3d. Cir. 1993).
I should note that the Clowes factors are not necessarily determinative. Courts engage in a broader inquiry: "an objective test to determine whether an employee can recover on a claim of constructive discharge ... [specifically,] whether a reasonable jury could find that the employer permitted conditions so unpleasant or difficult that a reasonable person would have felt compelled to resign." Woods; quoting Duffy v. Paper Magic Group, Inc., 265 F.3d 163, 167 (3d Cir.2001).