Wash. Court of Appeals published opinion — D2 49631-3-II Published Order.pdf

Citation: Wash. Court of Appeals published opinion — D2 49631-3-II Published Order.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/D2%2049631-3-II%20Published%20Order.pdf ↗

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49631-3-II

that the trial court did not err by granting summary judgment because no issue of material fact

remained and Billings’s retaliation claim could not succeed as a matter of law.

2. Public Policy Wrongful Discharge5

Billings argues that the trial court erred by granting summary judgment on his public policy

wrongful discharge claim because he pled a viable claim. He seems to argue that the related public

policy concerns were his role in the union opposing unlawful activity, waste of taxpayer money,

and his concerns about the town that violated WLAD.

“One narrow exception to the general at-will employment rule [in Washington] prohibits

an employer from discharging an employee ‘when the termination would frustrate a clear

manifestation of public policy.’” Roe v. TeleTech Customer Care Mgmt. (Colorado) LLC, 171

Wn.2d 736, 755, 257 P.3d 586 (2011) (quoting Ford v. Trendwest Resorts, Inc., 146 Wn.2d 146,

153, 43 P.3d 1223 (2002)). “The tort action is a ‘narrow public policy exception’ to the at-will

employment doctrine that balances the employee’s interest in job security and the employer’s

interest in making personnel decisions without fear of liability.” Roe, 171 Wn.2d at 755 (quoting

Thompson v. St. Regis Paper Co., 102 Wn.2d 219, 232, 685 P.2d 1081 (1984)). A public policy

wrongful discharge action may arise when: