Wash. Court of Appeals published opinion — 309941.cor.pdf

Citation: Wash. Court of Appeals published opinion — 309941.cor.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/309941.cor.pdf ↗

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legal argument to support the claim in his brief? No.

In his appeal brief, Jeff Brownfield devoted only two sentences to his claim for

failure to accommodate his disability. He wrote:

If the City perceived Ofc. Brownfield as unable to function in the most
stressful police work, the City owed an affirmative duty to Ofc. Brownfield
to accommodate him. The City failed to satisfy this duty not only when it

No. 30994-1-111
Brownfield v. City of Yakima

first took him out of a non-stressful position at which he excelled
[Community Services Division], but also when it transferred him to the
Patrol Unit, knowing it was a more stressful position both physically and
emotionally.

Br. of Appellant at 24-25.

In support of this contention, Brownfield quoted, in a footnote, a section

from the Washington Office of Financial Management Bulletin, State Policy

Guidelines on Reasonable Accommodation ofPersons with Disabilities Related to

State Employment. This bulletin has no application to this appeal, since Jeff

Brownfield was not a state employee. Brownfield's scant analysis of his

reasonable accommodation claim is not accompanied by any law that applies to

his circumstances or supports his contention. He cites no case law addressing a

failure to accommodate claim.

RAP 1O.3(a)(6) directs each party to supply, in his brief, "argument in support of

the issues presented for review, together with citations to legal authority and references to

relevant parts of the record." We do not consider conclusory arguments that are

unsupported by citation to authority. Joy v. Dep 't ofLabor & Indus., 170 Wn. App. 614,

629,285 P3d 187, 194-95 (2012). Passing treatment of an i~sue or lack of reasoned