Following the Supreme Court’s decision in Suders case, an individual who resigns can still claim constructive discharge by showing that the work environment became “so intolerable that a typical person in the employee’s position would have felt compelled to quit.” Federal law establishes guidelines related to constructive discharge claims. https://www.mtacorporate.com/when-resigning-counts-as-wrongful-termination-a-wrongful-termination-attorney-dc-guide-to-constructive-discharge/