employee immunity in Washington

2015“Instead, the inquiry is solely to decide whether the tort must be recognized to ensure that the public policy at issue is adequately protected.” Piel v. City of Federal Way, 177 Wn.2d 604, 623 , 306 P.3d 879 (2013) (Madsen, C.J., concurring in dissent). ¶23 The majority asserts that rejecting the adequacy analysis “merely eliminates a loophole for employers who intentionally contravene public policy to escape liability.” Majority at 260.

2015“Instead, the inquiry is solely to decide whether the tort must be recognized to ensure that the public policy at issue is adequately protected.” Piel v. City of Federal Way, 177 Wn.2d 604, 623 , 306 P.3d 879 (2013) (Madsen, C.J., concurring in dissent). ¶23 The majority asserts that rejecting the adequacy analysis “merely eliminates a loophole for employers who intentionally contravene public policy to escape liability.” Majority at 260.

2021They should not be tolerated anywhere and, in particular, have no place in a court of law. 7 Impark contends that the “[p]laintiffs spend much of their brief attacking an argument they falsely attribute to Impark: That a Hotel subcontractor must itself operate 100 or more guest rooms to be a covered Hospitality Employer.” While Impark does not make this argument, it is the logical extension of Impark’s interpretation of the ordinance to exclude a hotel’s employee requirement. 7 No. 80376-0-I/8 “avoid an interpretation that results in unlikely or strained consequences.” Swanson, 193 Wn.

2004Since we decline to reach that issue, we deny the Employee's motion to supplement the record. [1] Appellant argued the issue of reasonableness in Parts VI.A.7 and VI.C of the brief. [2] Ford v. Trendwest Resorts, Inc., 146 Wash.2d 146, 152 , 43 P.3d 1223 (2002); Thompson v. St.

2004Regis Paper Co., 102 Wash.2d 219, 223 , 685 P.2d 1081 (1984); Roberts v. Atl.

2004Regis Paper Co., 102 Wash.2d 219, 223 , 685 P.2d 1081 (1984); Roberts v. Atl.

2004Since we decline to reach that issue, we deny the Employee's motion to supplement the record. [1] Appellant argued the issue of reasonableness in Parts VI.A.7 and VI.C of the brief. [2] Ford v. Trendwest Resorts, Inc., 146 Wash.2d 146, 152 , 43 P.3d 1223 (2002); Thompson v. St.

1994Justice Andersen's dissent disputes this characterization of the law in Washington and argues that Guffey, Spurrell and Frost clearly establish that, where an employee has immunity, the State cannot be held liable on a respondeat superior theory. 116 Wn.2d at 620 . 7 See, e.g., Babcock, 116 Wn.2d at 621 ("we have acknowledged that policy considerations control the question of whether a government agency can take advantage of its agent’s immunity" (citing Creelman, 67 Wn.2d at 885 )); Lutheran Day Care, 119 Wn.2d at 127 (" 'public policy. . . requires immunity for both the state and the county

1994Justice Andersen's dissent disputes this characterization of the law in Washington and argues that Guffey, Spurrell and Frost clearly establish that, where an employee has immunity, the State cannot be held liable on a respondeat superior theory. 116 Wn.2d at 620 . 7 See, e.g., Babcock, 116 Wn.2d at 621 ("we have acknowledged that policy considerations control the question of whether a government agency can take advantage of its agent’s immunity" (citing Creelman, 67 Wn.2d at 885 )); Lutheran Day Care, 119 Wn.2d at 127 (" 'public policy. . . requires immunity for both the state and the county

1956Ed. 1025 , 74 S. Ct. 833 (1954) (Action for damages based on violent conduct). 29 U. S. C. 1952 ed. § 158 (b) provides: “It shall be an unfair labor practice for a labor organization or its agents— . . . “ (2) to cause or attempt to cause an employer to discriminate against an employee in violation of subsection (a) (3) of this section . . . ” 29 U. S. C. 1952 ed. § 158 (a) (3) provides: “ (a) It shall be an unfair labor practice for an employer— “ (3) by discrimination in regard to hire or tenure of employment or any term or condition of employment to en *524 courage or discourage membership