wrongful discharge claim (Alaska) · Go Syfert
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wrongful discharge claim in Alaska

6 Alaska opinions name it 1 courts 1986–2024 1 in the last five years

The cases below were cited by Alaska 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.

Followed or applied (10)

CaseFollowedCited
Okpik v. City of Barrowgreen
alaska · 2010 · cited in 2 Alaska opinions naming this issue, 2012–2024
2 sentences

2024Auth., 55 P.3d 57, 59 (Alaska 2002)). 9 Id. (citing Rice, 20 P.3d at 1102 n.7); Rice, 20 P.3d at 1102 n.7 (“Constructive discharge is not an independent cause of action, but merely satisfies the discharge element in a wrongful discharge claim.”). 10 Okpik, 230 P.3d at 679 (“An employer may breach the covenant objectively or subjectively.” (citing Witt v. State, Dep’t of Corr., 75 P.3d 1030, 1034 (Alaska 2003))).

2012DISCUSSION To prevail on a wrongful discharge claim, an employee must prove: “(1) that the employee was discharged by his or her employer and (2) that the employer breached a contract or committed a tort in connection with the employee’s termination.”10 In addition, “employees must first exhaust their contractual or administrative remedies, or show that they are excused from doing so, before they may pursue direct judicial actions against their employers.”11 If an employee fails to establish that an issue of material fact exists as to either of these grounds, or that the exhaustion requirement

22
Witt v. State, Department of Correctionsgreen
alaska · 2003 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024Auth., 55 P.3d 57, 59 (Alaska 2002)). 9 Id. (citing Rice, 20 P.3d at 1102 n.7); Rice, 20 P.3d at 1102 n.7 (“Constructive discharge is not an independent cause of action, but merely satisfies the discharge element in a wrongful discharge claim.”). 10 Okpik, 230 P.3d at 679 (“An employer may breach the covenant objectively or subjectively.” (citing Witt v. State, Dep’t of Corr., 75 P.3d 1030, 1034 (Alaska 2003))).

2024An employer objectively breaches the covenant when it “fails to act in a manner that a reasonable person would consider fair.” Id. (quoting Witt, 75 P.3d at 1034 ).

11
Charles v. Interior Regional Housing Authoritygreen
alaska · 2002 · cited in 1 Alaska opinions naming this issue, 2024–2024
2 sentences

2024Auth., 55 P.3d 57, 59 (Alaska 2002)). 9 Id. (citing Rice, 20 P.3d at 1102 n.7); Rice, 20 P.3d at 1102 n.7 (“Constructive discharge is not an independent cause of action, but merely satisfies the discharge element in a wrongful discharge claim.”). 10 Okpik, 230 P.3d at 679 (“An employer may breach the covenant objectively or subjectively.” (citing Witt v. State, Dep’t of Corr., 75 P.3d 1030, 1034 (Alaska 2003))).

2024Auth., 55 P.3d 57, 59 (Alaska 2002)). 9 Id. (citing Rice, 20 P.3d at 1102 n.7); Rice, 20 P.3d at 1102 n.7 (“Constructive discharge is not an independent cause of action, but merely satisfies the discharge element in a wrongful discharge claim.”). 10 Okpik, 230 P.3d at 679 (“An employer may breach the covenant objectively or subjectively.” (citing Witt v. State, Dep’t of Corr., 75 P.3d 1030, 1034 (Alaska 2003))).

11
State v. Beardgreen
alaska · 1998 · cited in 1 Alaska opinions naming this issue, 2012–2012
1 sentence

2012DISCUSSION To prevail on a wrongful discharge claim, an employee must prove: “(1) that the employee was discharged by his or her employer and (2) that the employer breached a contract or committed a tort in connection with the employee’s termination.”10 In addition, “employees must first exhaust their contractual or administrative remedies, or show that they are excused from doing so, before they may pursue direct judicial actions against their employers.”11 If an employee fails to establish that an issue of material fact exists as to either of these grounds, or that the exhaustion requirement

11
Cameron v. Beardgreen
alaska · 1993 · cited in 1 Alaska opinions naming this issue, 2012–2012
1 sentence

2012DISCUSSION To prevail on a wrongful discharge claim, an employee must prove: “(1) that the employee was discharged by his or her employer and (2) that the employer breached a contract or committed a tort in connection with the employee’s termination.”10 In addition, “employees must first exhaust their contractual or administrative remedies, or show that they are excused from doing so, before they may pursue direct judicial actions against their employers.”11 If an employee fails to establish that an issue of material fact exists as to either of these grounds, or that the exhaustion requirement

11
Wright v. Stategreen
alaska · 1992 · cited in 1 Alaska opinions naming this issue, 2012–2012
1 sentence

2012DISCUSSION To prevail on a wrongful discharge claim, an employee must prove: “(1) that the employee was discharged by his or her employer and (2) that the employer breached a contract or committed a tort in connection with the employee’s termination.”10 In addition, “employees must first exhaust their contractual or administrative remedies, or show that they are excused from doing so, before they may pursue direct judicial actions against their employers.”11 If an employee fails to establish that an issue of material fact exists as to either of these grounds, or that the exhaustion requirement

11
McCormick v. City of Dillinghamgreen
alaska · 2001 · cited in 1 Alaska opinions naming this issue, 2012–2012
1 sentence

2012DISCUSSION To prevail on a wrongful discharge claim, an employee must prove: “(1) that the employee was discharged by his or her employer and (2) that the employer breached a contract or committed a tort in connection with the employee’s termination.”10 In addition, “employees must first exhaust their contractual or administrative remedies, or show that they are excused from doing so, before they may pursue direct judicial actions against their employers.”11 If an employee fails to establish that an issue of material fact exists as to either of these grounds, or that the exhaustion requirement

11
Yost v. State, Division of Corporations, Business & Professional Licensinggreen
alaska · 2010 · cited in 1 Alaska opinions naming this issue, 2012–2012
1 sentence

2012DISCUSSION To prevail on a wrongful discharge claim, an employee must prove: “(1) that the employee was discharged by his or her employer and (2) that the employer breached a contract or committed a tort in connection with the employee’s termination.”10 In addition, “employees must first exhaust their contractual or administrative remedies, or show that they are excused from doing so, before they may pursue direct judicial actions against their employers.”11 If an employee fails to establish that an issue of material fact exists as to either of these grounds, or that the exhaustion requirement

11
Beard v. Baumgreen
alaska · 1990 · cited in 1 Alaska opinions naming this issue, 2000–2000
1 sentence

2000We recognized the doctrine of constructive discharge in Beard v. Baum, 796 P.2d 1344, 1349-50 (Alaska 1990). 8 .

11
Hawaiian Airlines, Inc. v. Norrisgreen
scotus · 1994 · cited in 1 Alaska opinions naming this issue, 1999–1999
2 sentences

1999See id.

1999See id.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Alaska. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
City of Fairbanks v. Rice green
alaska · 2000
2 sentences

2024Auth., 55 P.3d 57, 59 (Alaska 2002)). 9 Id. (citing Rice, 20 P.3d at 1102 n.7); Rice, 20 P.3d at 1102 n.7 (“Constructive discharge is not an independent cause of action, but merely satisfies the discharge element in a wrongful discharge claim.”). 10 Okpik, 230 P.3d at 679 (“An employer may breach the covenant objectively or subjectively.” (citing Witt v. State, Dep’t of Corr., 75 P.3d 1030, 1034 (Alaska 2003))).

2024Auth., 55 P.3d 57, 59 (Alaska 2002)). 9 Id. (citing Rice, 20 P.3d at 1102 n.7); Rice, 20 P.3d at 1102 n.7 (“Constructive discharge is not an independent cause of action, but merely satisfies the discharge element in a wrongful discharge claim.”). 10 Okpik, 230 P.3d at 679 (“An employer may breach the covenant objectively or subjectively.” (citing Witt v. State, Dep’t of Corr., 75 P.3d 1030, 1034 (Alaska 2003))).

12024–2024
State, Department of Highways v. Green green
alaska · 1978
1 sentence

2012DISCUSSION To prevail on a wrongful discharge claim, an employee must prove: “(1) that the employee was discharged by his or her employer and (2) that the employer breached a contract or committed a tort in connection with the employee’s termination.”10 In addition, “employees must first exhaust their contractual or administrative remedies, or show that they are excused from doing so, before they may pursue direct judicial actions against their employers.”11 If an employee fails to establish that an issue of material fact exists as to either of these grounds, or that the exhaustion requirement

12012–2012
Voigt v. Snowden green
alaska · 1996
1 sentence

2012DISCUSSION To prevail on a wrongful discharge claim, an employee must prove: “(1) that the employee was discharged by his or her employer and (2) that the employer breached a contract or committed a tort in connection with the employee’s termination.”10 In addition, “employees must first exhaust their contractual or administrative remedies, or show that they are excused from doing so, before they may pursue direct judicial actions against their employers.”11 If an employee fails to establish that an issue of material fact exists as to either of these grounds, or that the exhaustion requirement

12012–2012
Carlson v. Hutzel Corp. green
michctapp · 1990
2 sentences

1991Thus, the court in Carlson v. Hutzel Corp., 183 Mich.App. 508 , 455 N.W.2d 335 (1990), reversed submission of a wrongful discharge claim to a jury because “the grievance and arbitration procedure was a part of plaintiffs’ employment contract, and, as such, was plaintiffs’ sole remedy.” Id. 455 N.W.2d at 336 . 10 Similarly, the provisions for administrative review provided by the City became part of Diedrich’s contract.

1991Thus, the court in Carlson v. Hutzel Corp., 183 Mich.App. 508 , 455 N.W.2d 335 (1990), reversed submission of a wrongful discharge claim to a jury because “the grievance and arbitration procedure was a part of plaintiffs’ employment contract, and, as such, was plaintiffs’ sole remedy.” Id. 455 N.W.2d at 336 . 10 Similarly, the provisions for administrative review provided by the City became part of Diedrich’s contract.

11991–1991
State v. Haley green
alaska · 1984
1 sentence

1986In State v. Haley, 687 P.2d 305 (Alaska 1984), Haley, a legislative research assistant, brought a wrongful discharge claim against defendants nearly identical to those in the case at bar.

11986–1986

Where else courts name it

OH 61 (1990–2025) WA 45 (1990–2024) OR 40 (1984–2025) CT 39 (1987–2025) MI 27 (1984–2022) IA 26 (1992–2025) NC 25 (1991–2026) PA 25 (1985–2025) CA 24 (1985–2026) NJ 22 (1988–2025) MO 19 (1989–2020) TX 16 (1991–2023) MD 15 (1991–2017) MT 14 (1994–2024) DC 11 (1991–2018) NY 10 (1989–2026) WI 10 (1989–2023) CO 10 (1990–2023) WV 10 (1997–2023) UT 9 (1998–2015) KY 9 (1985–2026) MN 9 (1991–2016) AZ 8 (1988–2023) OK 7 (1989–2022) IN 7 (1992–2019) MA 7 (1993–2006) NH 7 (1999–2019) KS 7 (1984–2023) AK 6 (1986–2024) AR 5 (1988–2025) VI 5 (1994–2015) NM 5 (1991–2004) SC 5 (1996–2015) IL 4 (1984–2022) VA 4 (1996–2012) LA 4 (1991–2015) TN 4 (1997–2019) HI 3 (2011–2016) FL 3 (1989–2018) ME 2 (1986–2019) WY 2 (2009–2014) AL 2 (1986–2011) NE 2 (2006–2006) ID 2 (2003–2014) NV 2 (1991–1995) SD 2 (2006–2019)

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.

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