Can Wrongful Termination Claim be based on Voluntary Quit?

My phone rang early afternoon on Tuesday. A lady asked if I have a few minutes to listen to her story and determine if she has a valid wrongful termination claim. It turned out that she quit instead of being discharged by her employer. At the first glance, it doesn't seem to fit in the parameters of a "wrongful termination". However, it is noted that her decision to quit may have been a "constructive discharge" because her salary would be reduced to half and position would change from a manager supervising thirty plus people to one of those she oversaw.

Constructive discharge is a type of termination that is "quit" on surface but "discharge" in nature. It usually occurs when employer makes significant changes of employee's job responsibilities, demotes employee to a much lower position, or cut her compensation to a point of intolerance based on unlawful grounds, such as, race, religion, color, disability, nationality, age, etc. Under these circumstances, nobody would have been able to continue the job because of the humiliation and indignity she would suffer as a result of it, voluntary quit is but the only choice she has.

Interestingly, early next Morning, she called back telling me that her employer offered her job back last night. The ending was not too bad. I gave her something to take away - when you encounter a situation like this, don't quit on spot, calm down and give yourself just a few hours to think it through and perhaps consult with an attorney before making a wise decision.