Does a constructive discharge constitute a firing rather than a resignation?

Constructive discharge occurs when the employer's conduct effectively forces an employee to resign. Although the employee may say, "I [7 Cal.4th 1245] quit," the employment relationship is actually severed involuntarily by the employer's acts, against the employee's will. As a result, a constructive discharge is legally regarded as a firing rather than a resignation. (Zilmer v. Carnation Co. (1989) 215 Cal.App.3d 29, 38-39, 263 Cal.Rptr. 422 [hereafter Zilmer ].)