Bristow v. Daily Press, Inc.

How later courts describe this case

• recognizing that the law does not permit an employee's subjective perceptions to underlie a claim of constructive discharge because to do otherwise would be to enable an employee to base such a claim on unreasonable sensitivity to his work environs
• personal responsibility component of Poulis test met where party was aware of counsel's prior inability to comply with court rules
• a plaintiff must prove "deliberateness of the employer's action, and intolerability of the working conditions" to prove constructive discharge