I guess it depends on the circumstances. Like if they were told they could go full remote, and the employee moved out of state and settled down somewhere where there is no office, now to be told j/k get back in here, seems like a case could be made.
There is no case to be made in the US unless the constructive dismissal was discriminatory in nature. It is legal to get people to quit by making working conditions worse, as long as you don't break any employment laws by doing so.
Say that I want you some of my employees to quit. I say you are only allowed to have meetings while doing handstands, but I provide reasonable accommodation for disabled people who can't do handstands. If I fire you for not doing a handstand or if you quit because you don't want to do handstands, I have done nothing illegal under US law.
Doesn't mean it's a good system. But that is the system we have.
Constructive dismissal is legal. The point is that if an employee can show that you changed the rules to make them quit, they get unemployment benefits.
Especially if they were hired with remote in their original agreement. Changing the location of work would necessitate some additional consideration and a new agreement.
