In Jacobson v. Parda Federal Credit Union, 457 Mich 318; 577 NW2d 881 (1998), the Supreme Court of Michigan held that in a constructive discharge case brought under the WPA, the ninety-day statute of limitations begins to run from the date of the employee's resignation, but noted that in limited circumstances, such as delivery of notice of termination, a constructive discharge could be found to have occurred prior to resignation. Id., 327 n 20 The Jacobson Court did not hold that in any discharge case brought under the WPA, the ninety-day statute of limitations begins to run on the date an employee receives a notice of discharge. Jacobson, supra.