at-will employment doctrine in Washington

2015When the statute that declares the public policy also creates a remedy, the focus of the jeopardy analysis has centered on the adequacy of that remedy. 6 See Korslund v. DynCorp Tri-Cities Servs., Inc., 156 Wn.2d 168, 182-83 , 125 P.3d 119 (2005); Cudney v. ALSCO, Inc., 172 Wn.2d 524, 531-33 , 259 P.3d 244 (2011); Hubbard v. Spokane County, 146 Wn.2d 699, 717 , 50 P.3d 602 (2002). ¶46 “[T]his court has repeatedly applied [a] strict adequacy standard, holding that a tort of wrongful discharge in violation of public policy should be precluded unless the public policy is inadequately promoted thr

2015DynCorp Tri-Cities Servs., Inc., 156 Wn.2d 168, 182 , 125 P.3d 119 (2005). 4 Rose v. Anderson Hay & Grain Co., No. 90975-0 Fairhurst, J. (dissenting) "[T]his court has repeatedly applied [a] strict adequacy standard, holding that a tort of wrongful discharge in violation of public policy should be precluded unless the public policy 1s inadequately promoted through other means and thereby maintaining only a narrow exception to the underlying doctrine of at-will employment." Cudney, 172 Wn.2d at 530 .

2015When the statute that declares the public policy also creates a remedy, the focus of the jeopardy analysis has centered on the adequacy of that remedy. 6 See Korslund v. DynCorp Tri-Cities Servs., Inc., 156 Wn.2d 168, 182-83 , 125 P.3d 119 (2005); Cudney v. ALSCO, Inc., 172 Wn.2d 524, 531-33 , 259 P.3d 244 (2011); Hubbard v. Spokane County, 146 Wn.2d 699, 717 , 50 P.3d 602 (2002). ¶46 “[T]his court has repeatedly applied [a] strict adequacy standard, holding that a tort of wrongful discharge in violation of public policy should be precluded unless the public policy is inadequately promoted thr

2015DynCorp Tri-Cities Servs., Inc., 156 Wn.2d 168, 182 , 125 P.3d 119 (2005). 4 Rose v. Anderson Hay & Grain Co., No. 90975-0 Fairhurst, J. (dissenting) "[T]his court has repeatedly applied [a] strict adequacy standard, holding that a tort of wrongful discharge in violation of public policy should be precluded unless the public policy 1s inadequately promoted through other means and thereby maintaining only a narrow exception to the underlying doctrine of at-will employment." Cudney, 172 Wn.2d at 530 .

2011Id. ¶ 31 Gardner v. Loomis Armored, Inc., 128 Wash.2d 931 , 913 P.2d 377 (1996), refined the analysis of the action, recognizing that the action has generally arisen in the past in four situations: (1) where employees are fired for refusing to commit an illegal act; (2) where employees are fired for performing a public duty or obligation, such as serving jury duty; (3) where employees are fired for exercising a legal right or privilege, such as filing workers' compensation claims; and (4) where employees are fired in retaliation for reporting employer misconduct, i.e., whistleblowing.

2011Though Roe claims the divergence between Washington’s MUMA and federal drug law is of no consequence to a state tort claim for wrongful discharge, the two cannot be completely separated. 10 Holding that a broad public policy exists that would require an employer to allow an employee to engage in illegal activity would not be within Thompson’s directive to “ ‘proceed cautiously’ ” when finding a public policy exception to the at-will employment doctrine. 102 Wn.2d at 232 (emphasis omitted) (quoting Parnar, 652 P.2d at 631 ). ¶41 Roe has presented only one public policy argument to support her w

2026Martin v. Gonzaga Univ., 191 Wn.2d 712, 722-23 , 425 P.3d 837 (2018).

2026Martin v. Gonzaga Univ., 191 Wn.2d 712, 722-23 , 425 P.3d 837 (2018).

2011See Gardner, 128 Wash.2d at 945 , 913 P.2d 377 ; Hubbard, 146 Wash.2d at 713 , 50 P.3d 602 ; Korslund, 156 Wash.2d at 181-82 , 125 P.3d 119 ; Danny, 165 Wash.2d at 222 , 193 P.3d 128 . ¶ 10 In effect Cudney argues for the expansion of the "wrongful discharge against public policy" tort when he asks to proceed despite the existence of hardy statutory remedies that protect the relevant public policies.

2011See Gardner, 128 Wn.2d at 945 ; Hubbard, 146 Wn.2d at 713 ; Korslund, 156 Wn.2d at 181-82 ; Danny, 165 Wn.2d at 222 . ¶10 In effect Cudney argues for the expansion of the “wrongful discharge against public policy” tort when he asks to proceed despite the existence of hardy statutory remedies that protect the relevant public policies.

2002This illogical exception would swallow the at-will employment rule. [5] Sepanske v. Bendix Corp., 147 Mich.App. 819 , 384 N.W.2d 54 (1985) (per curiam); see also Clark v. Beverly Enters.-Mo., Inc., 872 S.W.2d 522 (Mo.Ct.App.1994); Bennett v. E.

2002This illogical exception would swallow the at-will employment rule. [5] Sepanske v. Bendix Corp., 147 Mich.App. 819 , 384 N.W.2d 54 (1985) (per curiam); see also Clark v. Beverly Enters.-Mo., Inc., 872 S.W.2d 522 (Mo.Ct.App.1994); Bennett v. E.

2021Sedlacek v. Hillis, 145 Wn.2d 379, 385 , 36 P.3d 1014 (2001).

2021Sedlacek v. Hillis, 145 Wn.2d 379, 385 , 36 P.3d 1014 (2001).

2017“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.

2015When the statute that declares the public policy also creates a remedy, the focus of the jeopardy analysis has centered on the adequacy of that remedy. 6 See Korslund v. DynCorp Tri-Cities Servs., Inc., 156 Wn.2d 168, 182-83 , 125 P.3d 119 (2005); Cudney v. ALSCO, Inc., 172 Wn.2d 524, 531-33 , 259 P.3d 244 (2011); Hubbard v. Spokane County, 146 Wn.2d 699, 717 , 50 P.3d 602 (2002). ¶46 “[T]his court has repeatedly applied [a] strict adequacy standard, holding that a tort of wrongful discharge in violation of public policy should be precluded unless the public policy is inadequately promoted thr

2011See Gardner, 128 Wash.2d at 945 , 913 P.2d 377 ; Hubbard, 146 Wash.2d at 713 , 50 P.3d 602 ; Korslund, 156 Wash.2d at 181-82 , 125 P.3d 119 ; Danny, 165 Wash.2d at 222 , 193 P.3d 128 . ¶ 10 In effect Cudney argues for the expansion of the "wrongful discharge against public policy" tort when he asks to proceed despite the existence of hardy statutory remedies that protect the relevant public policies.

2002Rebuilders, Inc., 52 N.C.App. 579 , 279 S.E.2d 46 (1981). [1] "The plaintiff Bobby Ford has the burden of proving each of the following propositions on the plaintiff's breach of contract claim: "(1) Trendwest entered into a contract with Bobby Ford; "(2) The terms of the contract included any one of the following promises: "a. to hold his job or position open while Ford participated in the EAP program; "b. to return him to work upon successful completion of the program; and "c. to return him to work during outpatient treatment. "(3) Trendwest Resorts breached the contract in one or more of the

2002Rebuilders, Inc., 52 N.C.App. 579 , 279 S.E.2d 46 (1981). [1] "The plaintiff Bobby Ford has the burden of proving each of the following propositions on the plaintiff's breach of contract claim: "(1) Trendwest entered into a contract with Bobby Ford; "(2) The terms of the contract included any one of the following promises: "a. to hold his job or position open while Ford participated in the EAP program; "b. to return him to work upon successful completion of the program; and "c. to return him to work during outpatient treatment. "(3) Trendwest Resorts breached the contract in one or more of the