When Does “I Quit” Actually Mean “I Quit”?
Dan Wilband
A recent Alberta Court of Justice decision clarifies what happens when employees try to withdraw resignations after the fact. In Corsini v Environmental 360 Solutions Ltd, 2025 ABCJ 132, the court rejected a wrongful dismissal claim, reinforcing some key principles every employer should know.
The Facts
The employee submitted a written resignation letter to her employer in August 2022, effective June 30, 2023. Her letter was clear: “Please accept this as my formal resignation, effective June 30th 2023.”
Later, during the company’s acquisition by a new owner in December 2022, the employee met with the new company’s COO. At trial, she claimed she verbally withdrew her resignation, saying she told the new owner she was “staying” and “no longer going to resign.” The new employer disagreed, maintaining she never retracted her resignation but only explored whether they might offer her a position in the new company.
In March 2023, the new employer advised the employee it did not have a position for her and it formally accepted her original resignation. The employee sued for wrongful dismissal, seeking $100,000. She lost.
The Legal Principles
The court applied established rules for resignations:
Resignations must be clear and unequivocal. Courts use a test that is both subjective (did the employee intend to resign?) and objective (would a reasonable employer understand they resigned?). The employee’s written letter satisfied both parts of the test.
Employees can withdraw resignations, but within limits. An employee can retract a resignation only if the employer has not accepted it or relied on it to its detriment. Once accepted or acted upon, the resignation is final.
Documentation matters. The court found the employer had already accepted and relied on the employee’s resignation before her alleged withdrawal attempt. Her resignation was in the due diligence files, known to management, and there was evidence that it factored into business decisions.
Why the Employer Won
Several factors secured the employer’s victory:
The original resignation letter was unambiguous. It contained no conditional language or uncertainty.
The employee’s own emails contradicted her testimony that she unequivocally withdrew her resignation, repeatedly stating she “would be willing to recant” her resignation for the right offer. This conditional language proved she never actually retracted it.
The evidence showed that the old employer had already accepted and acted on the resignation before any alleged withdrawal.
The corporate structure issue helped too: when the employee allegedly tried to withdraw her resignation in December 2022, she was still employed by her original company and the new owner was not yet directly involved. The new company’s representative had no authority to accept a withdrawal on the original employer’s behalf.
Key Takeaways for Employers
Document everything. The employer’s paper trail won this case. It’s important to confirm receipt of resignations in writing and keep detailed records of all related communications.
Act consistently. Once an employer accepts a resignation, it must conduct its business accordingly. If the resignation is included in planning, mentioned in meetings, and treated as final, this can establish the detrimental reliance that prevents later withdrawals.
Avoid ambiguity. In discussing potential future employment with a resigning employee, an employer shouldn’t create any false hope or confusion.
The Bottom Line
This case confirms that clear, written resignations create binding obligations. While employees do have a limited ability to withdraw resignations, employers who document things properly and act consistently will be able to rely on the resignation as a done deal.
The court’s message: when someone writes “I quit,” they mean it. Employers can rely on that decision, and employees can’t change their minds months later because better opportunities didn’t emerge.
Sometimes “I quit” really does mean “I quit.” But it’s important for both parties to handle resignations professionally and document everything.
This post discusses general legal principles, not specific legal advice. Consult qualified employment counsel for resignation-related issues.