Ames v. Nationwide Mutual Insurance Company

Issue: (1) Whether, in a constructive discharge case, the plaintiff must also prove, in addition to proving that discrimination created conditions so intolerable that a reasonable person would have felt compelled to resign, that the employer acted with the intent of forcing the plaintiff to resign; and (2) whether, in a constructive discharge case, the plaintiff must also prove that before resigning he or she complained sufficiently to the employer about the discrimination.