state tort claim (Washington) · Go Syfert
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state tort claim in Washington

6 Washington opinions name it 2 courts 1989–2012 0 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.

Followed or applied (3)

CaseFollowedCited
Thompson v. St. Regis Paper Companygreen
wash · 1984 · cited in 4 Washington opinions naming this issue, 2001–2011
2 sentences

2011Thompson, 102 Wash.2d at 232 , 685 P.2d 1081 . ¶ 40 Roe has presented only one public policy argument to support her wrongful termination claim—that MUMA broadly protects a patient's "personal, individual decision" to use medical marijuana.

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

14
Korslund v. DynCorp Tri-Cities Services, Inc.green
wash · 2005 · cited in 1 Washington opinions naming this issue, 2012–2012
1 sentence

2012See Korslund, 156 Wn.2d at 183 .

11
Pioneer First Federal Savings & Loan Ass'n v. Pioneer National Bankgreen
wash · 1983 · cited in 1 Washington opinions naming this issue, 1989–1989
1 sentence

1989Ed. 2d 791, 803 , 107 S. Ct. 2161 (1987) (because of the need for uniform interpretation, section 301 of the Labor Management Relations Act preempted a state tort claim); North Dakota v. Merchants Nat'l Bank & Trust Co., 634 F.2d 368 , 369 (8th Cir. 1980) (section 30 of the National Bank Act preempted state common law of unfair competition); Pioneer, 98 Wn.2d at 856 ("a federal enactment will preempt state statutory and common law" if there is actual conflict).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Parnar v. Americana Hotels, Inc. green
haw · 1982
1 sentence

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

12011–2011
State of North Dakota v. Merchants National Bank and Trust Company, Fargo, North Dakota green
ca8 · 1980
1 sentence

1989Ed. 2d 791, 803 , 107 S. Ct. 2161 (1987) (because of the need for uniform interpretation, section 301 of the Labor Management Relations Act preempted a state tort claim); North Dakota v. Merchants Nat'l Bank & Trust Co., 634 F.2d 368 , 369 (8th Cir. 1980) (section 30 of the National Bank Act preempted state common law of unfair competition); Pioneer, 98 Wn.2d at 856 ("a federal enactment will preempt state statutory and common law" if there is actual conflict).

11989–1989
International Brotherhood of Electrical Workers v. Hechler green
scotus · 1987
1 sentence

1989Ed. 2d 791, 803 , 107 S. Ct. 2161 (1987) (because of the need for uniform interpretation, section 301 of the Labor Management Relations Act preempted a state tort claim); North Dakota v. Merchants Nat'l Bank & Trust Co., 634 F.2d 368 , 369 (8th Cir. 1980) (section 30 of the National Bank Act preempted state common law of unfair competition); Pioneer, 98 Wn.2d at 856 ("a federal enactment will preempt state statutory and common law" if there is actual conflict).

11989–1989

Statutes the citing opinions construe

WA § Wash. Rev. Code § 49.60.040 (4)

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.

Where else courts name it

CA 15 (1983–2022) IL 14 (1986–2026) MN 8 (1975–2016) LA 8 (1987–2004) TX 8 (1996–2015) MS 7 (1999–2012) WA 6 (1989–2012) OH 5 (1987–2024) IA 5 (1985–2018) OK 5 (1990–2018) NM 4 (2001–2015) CT 4 (1997–2014) KS 4 (1993–2013) PA 4 (1995–2025) NC 4 (2001–2010) WI 3 (1984–2009) AZ 3 (1986–2019) NY 3 (1989–2023) MA 2 (1982–2023) WV 2 (1985–2009) MT 2 (1992–2002) MD 2 (1977–1992) AL 2 (1996–2003) MO 2 (1995–1996)

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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