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Wash. Supreme Court published opinion — 942099.pdf

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Wash. Supreme Court published opinion — 942099.pdf
Jurisdiction
Washington (state)
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Finally, discriminating against a person in "terms or conditions of

employment" because of race is clearly a practice forbidden by WLAD,and filing

a lawsuit for damages based on such discrimination is clearly opposing that

practice. RCW 49.60.180(3). Therefore, Zhu's prior lawsuit against Waterville

for racial discrimination in the terms and conditions of his employment constituted

opposition to a practice forbidden by WLAD.

Thus, all the elements of RCW 49.60.210(1) are met: An employer, ESD

171, discriminated against a person, Zhu, by refusing to hire him, and the jury

determined that it did so because Zhu opposed practices forbidden by WLAD by

suing Waterville for racial discrimination.

ESD 171, however, argues that the overall statutory context shows that the

legislature intended WLAD's antiretaliation provision to be significantly narrower

than WLAD's provisions prohibiting discrimination based on protected

characteristics, such that the antiretaliation provision applies only to a plaintiffs

current employer and prohibits only adverse actions that affect the plaintiffs

preexisting employment status. ESD 171 is correct that discerning a statute's plain

meaning requires us to consult the statute itself, "as well as related statutes or other

provisions ofthe same act in which the provision is found." Campbell & Gwinn,

10
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Jin Zhu V. ESD 171, No. 94209-9

LLC, 146 Wn.2d at 10. However,ESD ITl's interpretation is entirely inconsistent

with the plain language, structure, and purpose of WLAD as a whole. We

accordingly reject it.

2. As in the rest of WLAD,an "employer" is not limited to the plaintiffs
current employer for purposes of RCW 49.60.210(1)