refined analysis in Washington

2019In Gardner v. Loomis Armored, Inc., the Supreme Court clarified that there are four situations when the tort is recognized: (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. 128 Wn.2d 931, 936 , 913 P.2d 377 (1996). -5- No. 77538-3-1/6 When the employee's ca

2016Gardner, 128 Wn.2d at 941 (citing Henry H.

2019In Gardner v. Loomis Armored, Inc., the Supreme Court clarified that there are four situations when the tort is recognized: (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. 128 Wn.2d 931, 936 , 913 P.2d 377 (1996). -5- No. 77538-3-1/6 When the employee's ca

2019In Gardner v. Loomis Armored, Inc., the Supreme Court clarified that there are four situations when the tort is recognized: (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. 128 Wn.2d 931, 936 , 913 P.2d 377 (1996). -5- No. 77538-3-1/6 When the employee's ca

2019In Gardner v. Loomis Armored, Inc., the Supreme Court clarified that there are four situations when the tort is recognized: (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. 128 Wn.2d 931, 936 , 913 P.2d 377 (1996). -5- No. 77538-3-1/6 When the employee's ca

2001Id. at 941 , 913 P.2d 377 .

2015This court’s decisions prior to Gardner remain good law and are merely supplemented by the additional guidance provided by the Perritt factors. ¶17 In Hubbard v. Spokane County, 146 Wn.2d 699 , 50 P.3d 602 (2002), we departed from the precedent we had established by suggesting an additional requirement: the plaintiff must establish that no other statutory provision exists to adequately protect the public policy.

2015This court's decisions prior to Gardner remain good law and are merely supplemented by the additional guidance provided by the Perritt factors. 9 Rose v. Anderson Hay & Grain Co., No. 90975-0 In H~ubbard v. Spokane County, 146 Wn.2d 699 ; 50 P.3d 602 (2002), we departed from the precedent we had established by suggesting an additional requirement: the plaintiff must establish that no other statutory provision exists to adequately protect the public policy.

2015This court’s decisions prior to Gardner remain good law and are merely supplemented by the additional guidance provided by the Perritt factors. ¶17 In Hubbard v. Spokane County, 146 Wn.2d 699 , 50 P.3d 602 (2002), we departed from the precedent we had established by suggesting an additional requirement: the plaintiff must establish that no other statutory provision exists to adequately protect the public policy.

2015This court's decisions prior to Gardner remain good law and are merely supplemented by the additional guidance provided by the Perritt factors. 9 Rose v. Anderson Hay & Grain Co., No. 90975-0 In H~ubbard v. Spokane County, 146 Wn.2d 699 ; 50 P.3d 602 (2002), we departed from the precedent we had established by suggesting an additional requirement: the plaintiff must establish that no other statutory provision exists to adequately protect the public policy.

2018Anderson Hay & Grain Co., 184 Wash.2d 268 , 277-78, 287, 358 P.3d 1139 (2015) ("We note that in other instances, when the facts do not fit neatly into one of the four above-described categories, a more refined analysis may be necessary.

2018Anderson Hay & Grain Co., 184 Wash.2d 268 , 277-78, 287, 358 P.3d 1139 (2015) ("We note that in other instances, when the facts do not fit neatly into one of the four above-described categories, a more refined analysis may be necessary.

2018Recently, the Court refined this analysis, holding that "[t]he critical question under Garcetti is whether the speech at issue is itself ordinarily within the scope of an employee's duties, not whether it merely concerns those duties." Lane v. Franks, U.S. , 134 S. Ct. 2369, 2379 , 189 L.

2018Recently, the Court refined this analysis, holding that "[t]he critical question under Garcetti is whether the speech at issue is itself ordinarily within the scope of an employee's duties, not whether it merely concerns those duties." Lane v. Franks, U.S. , 134 S. Ct. 2369, 2379 , 189 L.