25 Washington opinions name it 2 courts 1957–2025 2 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Niece v. Elmview Group Homegreen2 sentences2025These causes of action are based on the theory that “such negligence on the part of the employer is a wrong to [the injured party], entirely independent of the liability of the employer under the doctrine of respondeat superior.” Id. at 48 (internal citations omitted) (quoting Scott, 50 Wn. 2022The court explained, that causes of action for negligent hiring, retention, and supervision are “based on the theory that ‘such negligence on the part of the employer is a wrong to [the injured party], entirely independent of the liability of the employer under the doctrine of respondeat superior.’” Niece, 131 Wn.2d at 48 (quoting Scott v. Blanchet High Sch., 50 Wn. | 3 | 4 |
Cleveland Board of Education v. Loudermillgreen2 sentences2014See Loudermill, 470 U. S. at 543 . 2014See Loudermill, 470 U.S. at 543 . | 2 | 2 |
SEATTLE PROFESSIONAL ENGINEERING EMP'S ASS'N v. Boeing Co.green2 sentences2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law). 2007See Cannon v. Miller, 22 Wash.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds, Seattle Prof'l Eng'g Employees Ass'n v. Boeing Co., 139 Wash.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal Labor Standards Act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law). | 2 | 2 |
Capital City Excavating Co., Inc. v. Raymond J. Donovan, Secretary of Labor, and Occupational Safety and Health Review Commissiongreen2 sentences2007Capital City Excavating Co. v. Donovan, 679 F.2d 105, 110 (6th Cir. 1982). 2007Capital City Excavating Co. v. Donovan 679 F.2d 105, 110 (6th Cir.1982). | 2 | 2 |
Seattle Professional Engineering Employees Ass'n v. Boeing Co.green2 sentences2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law). 2007See Cannon v. Miller, 22 Wash.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds, Seattle Prof'l Eng'g Employees Ass'n v. Boeing Co., 139 Wash.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal Labor Standards Act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law). | 2 | 2 |
SPEEA v. Boeing Co.green2 sentences2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law). 2007See Cannon v. Miller, 22 Wash.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds, Seattle Prof'l Eng'g Employees Ass'n v. Boeing Co., 139 Wash.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal Labor Standards Act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law). | 2 | 2 |
Cannon v. Millergreen2 sentences2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law). 2007See Cannon v. Miller, 22 Wn.2d 227, 238-39 , 155 P.2d 500 (1945), overruled on other grounds by Seattle Prof’l Eng’g Employees Ass’n v. Boeing Co., 139 Wn.2d 824 , 991 P.2d 1126 , 1 P.3d 578 (2000) (fact that employees accepted checks for lesser amounts did not preclude them from collecting amounts due them for overtime under the federal labor standards act, and employer could not assert an estoppel defense because it would permit the employer to relieve itself of liability imposed on the employer because of its violation of the law). | 2 | 2 |
Deeter v. Safeway Stores, Inc.green1 sentence1991But see Cagle v. Burns & Roe, Inc., 106 Wn.2d 911, 920-21 , 726 P.2d 434 (1986) (employee may recover for the tort of intentional infliction of emotional distress caused by termination of employment in violation of public policy); Deeter , at 75-76 (employees may bring action for tort of outrage based upon administration of claims). 3 RCW 51.48.025 provides: "(1) No employer may discharge or in any manner discriminate against any employee because such employee has filed or communicated to the employer an intent to file a claim for compensation or exercises any rights provided under this title. | 1 | 1 |
Carlson v. Smogardgreen2 sentences1978See Carlson v. Smogard, 298 Minn. 362 , 215 N.W.2d 615 (1974); Sunspan Eng'r & Constr. 1978See Carlson v. Smogard, 298 Minn. 362 , 215 N.W.2d 615 (1974); Sunspan Eng'r & Constr. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Cagle v. Burns and Roe, Inc.green2 sentences1991But see Cagle v. Burns & Roe, Inc., 106 Wn.2d 911, 920-21 , 726 P.2d 434 (1986) (employee may recover for the tort of intentional infliction of emotional distress caused by termination of employment in violation of public policy); Deeter , at 75-76 (employees may bring action for tort of outrage based upon administration of claims). 3 RCW 51.48.025 provides: "(1) No employer may discharge or in any manner discriminate against any employee because such employee has filed or communicated to the employer an intent to file a claim for compensation or exercises any rights provided under this title. 1991But see Cagle v. Burns & Roe, Inc., 106 Wn.2d 911, 920-21 , 726 P.2d 434 (1986) (employee may recover for the tort of intentional infliction of emotional distress caused by termination of employment in violation of public policy); Deeter , at 75-76 (employees may bring action for tort of outrage based upon administration of claims). 3 RCW 51.48.025 provides: "(1) No employer may discharge or in any manner discriminate against any employee because such employee has filed or communicated to the employer an intent to file a claim for compensation or exercises any rights provided under this title. | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
Scott v. Blanchet High School
green
2 sentences2025These causes of action are based on the theory that “such negligence on the part of the employer is a wrong to [the injured party], entirely independent of the liability of the employer under the doctrine of respondeat superior.” Id. at 48 (internal citations omitted) (quoting Scott, 50 Wn. 2022The court explained, that causes of action for negligent hiring, retention, and supervision are “based on the theory that ‘such negligence on the part of the employer is a wrong to [the injured party], entirely independent of the liability of the employer under the doctrine of respondeat superior.’” Niece, 131 Wn.2d at 48 (quoting Scott v. Blanchet High Sch., 50 Wn. | 8 | 1997–2025 |
Buckley & Company, Inc. v. Secretary of Labor
neutral
2 sentences2007Under that formulation of the test, so long as the Department’s notice is likely to be passed along to the appropriate officials, service is appropriate. ¶36 Washington Cedar cites Buckley & Co. v. Secretary of Labor, 507 F.2d 78 (3d Cir. 1975). 4 In Buckley, the federal Third Circuit Court of Appeals reviewed an administrative ruling that an employer could not challenge a citation because the employer had not responded within 15 days of receiving notice of the citation. 2007Under that formulation of the test, so long as the Department's notice is likely to be passed along to the appropriate officials, service is appropriate. ¶ 36 Washington Cedar cites Buckley & Company., Inc. v. Secretary of Labor, 507 F.2d 78 (3d Cir.1975). [4] In Buckley, the Federal Third Circuit Court of Appeals reviewed an administrative ruling that an employer could not challenge a citation because the employer had not responded within 15 days of receiving notice of the citation. | 2 | 2007–2007 |
Ellis v. City of Seattle
green
2 sentences2002In Ellis, the court did not examine whether the plaintiff had established the clarity element because the employer did not challenge the Court of Appeals holding that the employee had established a clear mandate of public policy that satisfied the clarity element. 142 Wash.2d at 459-60 , 13 P.3d 1065 . 2002In Ellis , the court did not examine whether the plaintiff had established the clarity element because the employer did not challenge the Court of Appeals holding that the employee had established a clear mandate of public policy that satisfied the clarity element. 142 Wn.2d at 459-60 . | 2 | 2002–2002 |
LaPlant v. Snohomish County
green
1 sentence2014The theories are not entirely independent, however: we have held that " a claim for negligent hiring, training, and supervision is generally improper when the employer concedes the employee' s actions occurred within the course and scope of employment." LaPlant v. Snohomish County, 162 Wn. | 1 | 2014–2014 |
Ellis v. City of Seattle
green
1 sentence2002In Ellis, the court did not examine whether the plaintiff had established the clarity element because the employer did not challenge the Court of Appeals holding that the employee had established a clear mandate of public policy that satisfied the clarity element. 142 Wash.2d at 459-60 , 13 P.3d 1065 . | 1 | 2002–2002 |
Sedlacek v. Hillis
green
1 sentence2002In Sedlacek, the court never had to determine whether the public policy had been contravened, because it concluded that there was no clear mandate of public policy in Washington supporting the claim. 145 Wn.2d at 393 . | 1 | 2002–2002 |
Niece v. Elmview Group Home
green
1 sentence2002Niece, 131 Wash.2d at 48 , 929 P.2d 420 (alteration in original). [9] Indeed, prior to Snyder, Washington case law regarding intentional torts and vicarious liability was mostly confined to sexual misconduct; naturally, the courts have held that the sexual acts of employees are not within the scope of employment. | 1 | 2002–2002 |
Sedlacek v. Hillis
green
1 sentence2002In Sedlacek, the court never had to determine whether the public policy had been contravened, because it concluded that there was no clear mandate of public policy in Washington supporting the claim. 145 Wash.2d at 393, 36 P.3d 1014 . [17] See also Spokane County Zoning Code 14.100.104 ("[t]he general purpose of this Zoning Code is to promote the health, safety, and general welfare"). [18] In his letter to the hotel developer's counsel, Emacio refers to the airport master plan as a "binding site plan," which is governed by chapter 58.17 RCW. | 1 | 2002–2002 |
Guild v. Saint Martin's College
green
1 sentence1997App. 491, 498-99 , 827 P.2d 286 , review denied, 119 Wn.2d 1016 (1992). " 'The theory of these decisions is that such negligence on the part of the employer is a wrong to such third person, entirely independent of the liability of the employer under the doctrine of respondeat superior.’ ” Peck v. Siau, 65 Wn. | 1 | 1997–1997 |
Peck v. Siau
green
2 sentences1997App. 491, 498-99 , 827 P.2d 286 , review denied, 119 Wn.2d 1016 (1992). " 'The theory of these decisions is that such negligence on the part of the employer is a wrong to such third person, entirely independent of the liability of the employer under the doctrine of respondeat superior.’ ” Peck v. Siau, 65 Wn. 1997App. 285, 288 , 827 P.2d 1108 (quoting Scott v. Blanchet High Sch., 50 Wn. | 1 | 1997–1997 |
Dickinson v. Edwards
green
1 sentence1993Dickinson, 105 Wn.2d at 468 . 2 The other side of the "within the scope" argument is found in Simmons v. United States, 805 F.2d 1363 (9th Cir. 1986), 3 which cites to the Washington case of Smith v. Leber, 34 Wn.2d 611 , 209 P.2d 297 (1949). | 1 | 1993–1993 |
Jerrie M. Simmons v. United States
green
1 sentence1993Dickinson, 105 Wn.2d at 468 . 2 The other side of the "within the scope" argument is found in Simmons v. United States, 805 F.2d 1363 (9th Cir. 1986), 3 which cites to the Washington case of Smith v. Leber, 34 Wn.2d 611 , 209 P.2d 297 (1949). | 1 | 1993–1993 |
Smith v. Leber
green
2 sentences1993Dickinson, 105 Wn.2d at 468 . 2 The other side of the "within the scope" argument is found in Simmons v. United States, 805 F.2d 1363 (9th Cir. 1986), 3 which cites to the Washington case of Smith v. Leber, 34 Wn.2d 611 , 209 P.2d 297 (1949). 1993Dickinson, 105 Wn.2d at 468 . 2 The other side of the "within the scope" argument is found in Simmons v. United States, 805 F.2d 1363 (9th Cir. 1986), 3 which cites to the Washington case of Smith v. Leber, 34 Wn.2d 611 , 209 P.2d 297 (1949). | 1 | 1993–1993 |
Nelson v. Department of Employment Security
green
2 sentences1992Sec., 98 Wn.2d 370, 374-75 , 655 P.2d 242 (1982) as adopted by Macey. 1992Sec., 98 Wn.2d 370, 374-75 , 655 P.2d 242 (1982) as adopted by Macey. | 1 | 1992–1992 |
Dean v. Municipality of Metropolitan Seattle
green
2 sentences1987Dean v. Metropolitan Seattle, 104 Wn.2d 627, 632 , 708 P.2d 393 (1985). 1987Dean v. Metropolitan Seattle, 104 Wn.2d 627, 632 , 708 P.2d 393 (1985). | 1 | 1987–1987 |
Calkins v. Lorain Division of Koehring Co.
green
2 sentences1982Calkins v. Lorain Div. of Koehring Co., 26 Wn. 1982Calkins v. Lorain Div. of Koehring Co., 26 Wn. | 1 | 1982–1982 |
Blackford v. Sioux City Dressed Pork, Inc.
green
2 sentences1978Murch Co., 87 Wn.2d 203 , 550 P.2d 506 (1976) (in which the court stressed the broad nature of the exclusionary language of RCW 51.04.010 while rejecting the tort claim of third-party parents for the alleged wrongful death of their minor employee son). [3] I agree with the Supreme Court of Iowa when it stated, "An intention of the legislature, in enacting a statute for the regulation of rights between the employer and employee, to destroy the rights of third parties should at the very least be clearly expressed." Blackford v. Sioux City Dressed Pork, Inc., 254 Iowa 845, 855 , 118 N.W.2d 559 (1 1978Murch Co., 87 Wn.2d 203 , 550 P.2d 506 (1976) (in which the court stressed the broad nature of the exclusionary language of RCW 51.04.010 while rejecting the tort claim of third-party parents for the alleged wrongful death of their minor employee son). [3] I agree with the Supreme Court of Iowa when it stated, "An intention of the legislature, in enacting a statute for the regulation of rights between the employer and employee, to destroy the rights of third parties should at the very least be clearly expressed." Blackford v. Sioux City Dressed Pork, Inc., 254 Iowa 845, 855 , 118 N.W.2d 559 (1 | 1 | 1978–1978 |
Ledesma v. A. F. Murch Co.
green
2 sentences1978Murch Co., 87 Wn.2d 203 , 550 P.2d 506 (1976) (in which the court stressed the broad nature of the exclusionary language of RCW 51.04.010 while rejecting the tort claim of third-party parents for the alleged wrongful death of their minor employee son). [3] I agree with the Supreme Court of Iowa when it stated, "An intention of the legislature, in enacting a statute for the regulation of rights between the employer and employee, to destroy the rights of third parties should at the very least be clearly expressed." Blackford v. Sioux City Dressed Pork, Inc., 254 Iowa 845, 855 , 118 N.W.2d 559 (1 1978Murch Co., 87 Wn.2d 203 , 550 P.2d 506 (1976) (in which the court stressed the broad nature of the exclusionary language of RCW 51.04.010 while rejecting the tort claim of third-party parents for the alleged wrongful death of their minor employee son). [3] I agree with the Supreme Court of Iowa when it stated, "An intention of the legislature, in enacting a statute for the regulation of rights between the employer and employee, to destroy the rights of third parties should at the very least be clearly expressed." Blackford v. Sioux City Dressed Pork, Inc., 254 Iowa 845, 855 , 118 N.W.2d 559 (1 | 1 | 1978–1978 |
Greenleaf v. Puget Sound Bridge & Dredging Co.
green
2 sentences1970Greenleaf v. Puget Sound Bridge & Dredging Co., 58 Wn.2d 647 , 364 P.2d 796 (1961). 1970Greenleaf v. Puget Sound Bridge & Dredging Co., 58 Wn.2d 647 , 364 P.2d 796 (1961). | 1 | 1970–1970 |
| Langness v. Ketonen neutral | 1 | 1957–1957 |
James v. Ellis
green
1 sentence1957James v. Ellis, 44 Wn. (2d) 599, 269 P. (2d) 573 ; Langness v. Ketonen, 42 Wn. (2d) 394, 255 P. (2d) 551 ; Skrivanich v. Davis, 29 Wn. (2d) 150, 186 P. (2d) 364 ; D’Amico v. Conquisto, 24 Wn. (2d) 674, 167 P. (2d) 157 . | 1 | 1957–1957 |
| Skrivanich v. Davis green | 1 | 1957–1957 |
| D'Amico v. Conguista green | 1 | 1957–1957 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.