45 Washington opinions name it 2 courts 1990–2024 3 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.
| Case | Followed | Cited |
|---|---|---|
Gardner v. Loomis Armored, Inc.green2 sentences2017A wrongful discharge in violation of a public policy claim has four elements: (1) The plaintiffs must prove the existence of a clear public policy (the clarity element). (2) The plaintiffs must prove that discouraging the conduct in which they engaged would jeopardize the public policy (the jeopardy element). (3) The plaintiffs must prove that the public-policy-linked conduct caused the dismissal (the causation element). (4) The defendant must not be able to offer an overriding justification for the dismissal (the absence of justification element).126] "To establish jeopardy, the plaintiff mus 2017A wrongful discharge in violation of a public policy claim has four elements: (1) The plaintiffs must prove the existence of a clear public policy (the clarity element). (2) The plaintiffs must prove that discouraging the conduct in which they engaged would jeopardize the public policy (the jeopardy element). (3) The plaintiffs must prove that the public-policy-linked conduct caused the dismissal (the causation element). (4) The defendant must not be able to offer an overriding justification for the dismissal (the absence of justification element).126] "To establish jeopardy, the plaintiff mus | 3 | 7 |
Roberts v. Dudleygreen2 sentences2001Finally, this court recently extended the wrongful discharge doctrine in Roberts v. Dudley, 140 Wash.2d 58 , 993 P.2d 901 (2000). 2001Finally, this court recently extended the wrongful discharge doctrine in Roberts v. Dudley, 140 Wn.2d 58 , 993 P.2d 901 (2000). | 3 | 4 |
Gardner v. Loomis Armored Inc.green2 sentences2017A wrongful discharge in violation of a public policy claim has four elements: (1) The plaintiffs must prove the existence of a clear public policy (the clarity element). (2) The plaintiffs must prove that discouraging the conduct in which they engaged would jeopardize the public policy (the jeopardy element). (3) The plaintiffs must prove that the public-policy-linked conduct caused the dismissal (the causation element). (4) The defendant must not be able to offer an overriding justification for the dismissal (the absence of justification element).126] "To establish jeopardy, the plaintiff mus 2009Id. at 935-36 , 913 P.2d 377 . ¶ 50 To prove a claim for a wrongful discharge in violation of public policy, Ms. Hollenback must establish: (1) the existence of a clear public policy, known as the clarity element; (2) that discouraging the conduct in which Ms. Hollenback engaged would jeopardize the public policy, known as the jeopardy element; (3) that the public policy-linked conduct caused dismissal, known as the causation element; and (4) that Shriners cannot offer an overriding justification for the dismissal, known as the absence of justification element. | 2 | 6 |
Bravo v. Dolsen Companiesgreen2 sentences2009Bravo, 125 Wn.2d at 758 (requiring discharge to establish a prima facie action for the tort of wrongful discharge in violation of public policy). 1995Furthermore, because the statute expresses an important public policy of this state, the court held that RCW 49.32.020 also gives rise to a tort cause of action for a wrongful discharge in violation of public policy. 125 Wn.2d at 758 . | 2 | 3 |
Raynes v. City of Leavenworthgreen2 sentences2000See Raynes v. City of Leavenworth, 118 Wn.2d 237, 243 , 821 P.2d 1204 (1992) (“[T]he appropriate remedy when legislative action is considered unjust is political.”) By allowing a wrongful discharge claim based on a public policy against gender discrimination, the majority has done just that. 2000See Raynes v. City of Leavenworth, 118 Wn.2d 237, 243 , 821 P.2d 1204 (1992) (“[T]he appropriate remedy when legislative action is considered unjust is political.”) By allowing a wrongful discharge claim based on a public policy against gender discrimination, the majority has done just that. | 2 | 2 |
Zimmerman v. Buchheit of Sparta, Inc.green2 sentences1997See, e.g., Zimmerman v. Buchheit of Sparta, Inc., 164 Ill.2d 29 , 206 Ill.Dec. 625 , 645 N.E.2d 877 (1994) (refusing to extend the tort of wrongful discharge to include demotions); Ludwig v. C & A Wallcoverings, Inc., 960 F.2d 40 (7th Cir.1992) (employee cannot bring a wrongful discharge claim for retaliatory discharge when she was merely demoted); Mintz v. Bell Atlantic Sys. 1997See, e.g., Zimmerman v. Buchheit of Sparta, Inc., 164 Ill.2d 29 , 206 Ill.Dec. 625 , 645 N.E.2d 877 (1994) (refusing to extend the tort of wrongful discharge to include demotions); Ludwig v. C & A Wallcoverings, Inc., 960 F.2d 40 (7th Cir.1992) (employee cannot bring a wrongful discharge claim for retaliatory discharge when she was merely demoted); Mintz v. Bell Atlantic Sys. | 2 | 2 |
Thompson v. St. Regis Paper Companygreen2 sentences2013Regis Paper Co., 102 Wn.2d 219, 225 , 685 P.2d 1081 (1984) (breach of promise). ¶16 The wrongful discharge in violation of public policy is a narrow exception, and courts must “ ‘proceed cautiously.’ ” Thompson, 102 Wn.2d at 232 (emphasis omitted) (quoting Parnar v. Americana Hotels, Inc., 65 Haw. 370, 380 , 652 P.2d 625 (1982)). 2013Regis Paper Co., 102 Wn.2d 219, 225 , 685 P.2d 1081 (1984) (breach of promise). ¶16 The wrongful discharge in violation of public policy is a narrow exception, and courts must “ ‘proceed cautiously.’ ” Thompson, 102 Wn.2d at 232 (emphasis omitted) (quoting Parnar v. Americana Hotels, Inc., 65 Haw. 370, 380 , 652 P.2d 625 (1982)). | 1 | 8 |
Hubbard v. Spokane Countygreen2 sentences2013Hubbard v. Spokane County, 146 Wn.2d 699, 713 , 50 P.3d 602 (2002). 2013See Hubbard v. Spokane County, 146 Wn.2d 699, 713 , 50 P.3d 602 (2002). ¶19 The Washington health care act (WHCA), chapter 43.70 RCW, provides comprehensive remedies to Ms. Worley to promote the public policy claim. | 1 | 4 |
Hubbard v. SPOKENE COUNTYgreen2 sentences2013Hubbard v. Spokane County, 146 Wn.2d 699, 713 , 50 P.3d 602 (2002). 2013See Hubbard v. Spokane County, 146 Wn.2d 699, 713 , 50 P.3d 602 (2002). ¶19 The Washington health care act (WHCA), chapter 43.70 RCW, provides comprehensive remedies to Ms. Worley to promote the public policy claim. | 1 | 4 |
Roberts v. Dudleygreen2 sentences2001Finally, this court recently extended the wrongful discharge doctrine in Roberts v. Dudley, 140 Wash.2d 58 , 993 P.2d 901 (2000). 2001Finally, this court recently extended the wrongful discharge doctrine in Roberts v. Dudley, 140 Wn.2d 58 , 993 P.2d 901 (2000). | 1 | 3 |
Ellis v. City of Seattlegreen2 sentences2011See Roberts, 140 Wash.2d at 77 , 993 P.2d 901 ; Bennett, 113 Wash.2d at 929 , 784 P.2d 1258 ; cf. Ellis, 142 Wash.2d at 461 , 13 P.3d 1065 (noting, "Ellis is not required to prove an actual WISHA violation. 2011See Roberts, 140 Wn.2d at 77 ; Bennett, 113 Wn.2d at 929 ; cf. Ellis, 142 Wn.2d at 461 (noting, “Ellis is not required to prove an actual WISHA violation. | 1 | 2 |
Becker v. Community Health Systems, Inc.green2 sentences2023When there has been an actual discharge, the elements for a wrongful discharge in violation of public policy claim are “(1) the employee’s discharge may have been motivated by reasons that contravene a clear mandate of public policy, and (2) the public-policy-linked conduct was a significant factor in the decision to discharge the worker.” Id. at 829. 2023When the wrongful discharge in violation of public policy claim arises from constructive discharge, the first element “is modified to address whether the intolerable condition that led the employee to resign contravened a clear mandate of public policy.” Id. at 830. 8 No. 57026-2-II The second element also differs depending on whether the claim is based on actual or constructive discharge. | 1 | 1 |
| Rickman v. Premera Blue Crossgreen | 1 | 1 |
| Roberts v. Auto. Club of Mich.green | 1 | 1 |
| Zwick v. United Statesgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| Korslund v. DynCorp Tri-Cities Services, Inc.green | 1 | 1 |
| Korslund v. Dyncorp Tri-Cities Servicesgreen | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
Wilmot v. Kaiser Aluminum & Chemical Corp.
green
2 sentences2008In Wilmot, 118 Wash.2d at 75 , 821 P.2d 18 , this court recognized this distinction in the context of a wrongful discharge claim alleging an employer discharged an employee for filing a worker's compensation claim. 2008In Wilmot, 118 Wn.2d at 75 , this court recognized this distinction in the context of a wrongful discharge claim alleging an employer discharged an employee for filing a workers’ compensation claim. | 5 | 1995–2016 |
Smith v. Bates Technical College
green
2 sentences2013In Smith, we noted that Reninger made it “even more compelling” to hold that the public policy tort does not require first pursuing PERC administrative remedies. 139 Wn.2d at 810 . 2013In Smith, we noted that Reninger made it "even more compelling" to hold that the public policy tort does not require first pursuing PERC administrative remedies. 139 Wn.2d at 810 . | 3 | 2000–2013 |
Parnar v. Americana Hotels, Inc.
green
2 sentences2013Regis Paper Co., 102 Wn.2d 219, 225 , 685 P.2d 1081 (1984) (breach of promise). ¶16 The wrongful discharge in violation of public policy is a narrow exception, and courts must “ ‘proceed cautiously.’ ” Thompson, 102 Wn.2d at 232 (emphasis omitted) (quoting Parnar v. Americana Hotels, Inc., 65 Haw. 370, 380 , 652 P.2d 625 (1982)). 2013Regis Paper Co., 102 Wn.2d 219, 225 , 685 P.2d 1081 (1984) (breach of promise). ¶16 The wrongful discharge in violation of public policy is a narrow exception, and courts must “ ‘proceed cautiously.’ ” Thompson, 102 Wn.2d at 232 (emphasis omitted) (quoting Parnar v. Americana Hotels, Inc., 65 Haw. 370, 380 , 652 P.2d 625 (1982)). | 2 | 2013–2013 |
Reninger v. Department of Corrections
green
2 sentences2013In Reninger v. Department of Corrections, 134 Wn.2d 437 , 951 P.2d 782 (1998), we held that an employee who loses in an administrative proceeding (there, a personnel appeals board hearing) may be collaterally estopped from asserting a wrongful discharge claim. 2013In Reninger v. Department of Corrections, 134 Wn.2d 437 , 951 P.2d 782 (1998), we held that an employee who loses in an administrative proceeding (there, a personnel appeals board hearing) may be collaterally estopped from asserting a wrongful discharge claim. | 2 | 2013–2013 |
Reninger v. State Dept. of Corrections
green
2 sentences2013In Reninger v. Department of Corrections, 134 Wn.2d 437 , 951 P.2d 782 (1998), we held that an employee who loses in an administrative proceeding (there, a personnel appeals board hearing) may be collaterally estopped from asserting a wrongful discharge claim. 2013In Reninger v. Department of Corrections, 134 Wn.2d 437 , 951 P.2d 782 (1998), we held that an employee who loses in an administrative proceeding (there, a personnel appeals board hearing) may be collaterally estopped from asserting a wrongful discharge claim. | 2 | 2013–2013 |
Bennett v. Hardy
green
2 sentences2011See Roberts, 140 Wash.2d at 77 , 993 P.2d 901 ; Bennett, 113 Wash.2d at 929 , 784 P.2d 1258 ; cf. Ellis, 142 Wash.2d at 461 , 13 P.3d 1065 (noting, "Ellis is not required to prove an actual WISHA violation. 2011See Roberts, 140 Wn.2d at 77 ; Bennett, 113 Wn.2d at 929 ; cf. Ellis, 142 Wn.2d at 461 (noting, “Ellis is not required to prove an actual WISHA violation. | 2 | 2011–2011 |
Sedlacek v. Hillis
green
2 sentences2011This court has recognized, however, "that the tort of wrongful discharge in violation of public policy is a narrow exception to the employment at-will doctrine." Id. ¶ 7 To prevail on a wrongful discharge claim, a plaintiff must satisfy a four-factor test. 2011This court has recognized, however, “that the tort of wrongful discharge in violation of public policy is a narrow exception to the employment at-will doctrine.” Id. ¶7 To prevail on a wrongful discharge claim, a plaintiff must satisfy a four-factor test. | 2 | 2011–2011 |
American Colloid Co. v. Eastern Clay Products, Inc.
green
2 sentences2009Id.; Martin, 207 F.2d at 658 . ¶ 81 My colleague Justice Charles Johnson acknowledges that this court has opined that constructive discharge may support a wrongful discharge claim. 2009Id.; Martin, 207 F.2d at 658 . ¶81 My colleague Justice Charles Johnson acknowledges that this court has opined that constructive discharge may support a wrongful discharge claim. | 2 | 2009–2009 |
State v. Freeman
neutral
2 sentences2009Briggs v. Nova Services, 161 Wash.2d 1022 , 172 P.3d 360 (2007). *914 ANALYSIS ¶ 11 We review an order granting summary judgment de novo. 2009Briggs v. Nova Servs., 161 Wn.2d 1022 , 172 P.3d 360 (2007). | 2 | 2009–2009 |
In Re Marriage of Kowalewski
neutral
2 sentences2009Briggs v. Nova Services, 161 Wash.2d 1022 , 172 P.3d 360 (2007). *914 ANALYSIS ¶ 11 We review an order granting summary judgment de novo. 2009Briggs v. Nova Servs., 161 Wn.2d 1022 , 172 P.3d 360 (2007). | 2 | 2009–2009 |
Christensen v. Grant County Hospital District No. 1
green
2 sentences2008In Christensen, 152 Wn.2d at 321 , the Court held that an employee’s failed action before the Public Employees Relations Commission collaterally estopped him from bringing a wrongful discharge claim in superior court. 2008In Christensen, 152 Wash.2d at 321 , 96 P.3d 957 , the Court held that an employee's failed action before the Public Employees Relations Commission collaterally estopped him from bringing a wrongful discharge claim in superior court. | 2 | 2008–2008 |
Douchette v. Bethel School District No. 403
green
2 sentences2001No. 403, 117 Wn.2d 805, 816 , 818 P.2d 1362 (1991) (approving of the Court of Appeals’ reliance on federal case law to determine when a wrongful discharge claim accrues). 2001No. 403, 117 Wn.2d 805, 816 , 818 P.2d 1362 (1991) (approving of the Court of Appeals’ reliance on federal case law to determine when a wrongful discharge claim accrues). | 2 | 2001–2001 |
Mintz v. Bell Atlantic Systems Leasing International, Inc.
green
2 sentences1997Leasing Int'l, Inc., 183 Ariz. 550 , 905 P.2d 559 (1995) (a public policy tort for failure to promote does not exist and it is unnecessary for courts to create one); Foley v. Interactive Data Corp., 47 Cal.3d 654 , 254 Cal.Rptr. 211 , 765 P.2d 373 (1988) (expansion of tort remedies in employment actions has potential for enormous consequence in the stability of the business community); Scott v. Pacific Gas & Elec. 1997Leasing Int'l, Inc., 183 Ariz. 550 , 905 P.2d 559 (1995) (a public policy tort for failure to promote does not exist and it is unnecessary for courts to create one); Foley v. Interactive Data Corp., 47 Cal.3d 654 , 254 Cal.Rptr. 211 , 765 P.2d 373 (1988) (expansion of tort remedies in employment actions has potential for enormous consequence in the stability of the business community); Scott v. Pacific Gas & Elec. | 2 | 1997–1997 |
Foley v. Interactive Data Corp.
green
2 sentences1997Leasing Int'l, Inc., 183 Ariz. 550 , 905 P.2d 559 (1995) (a public policy tort for failure to promote does not exist and it is unnecessary for courts to create one); Foley v. Interactive Data Corp., 47 Cal.3d 654 , 254 Cal.Rptr. 211 , 765 P.2d 373 (1988) (expansion of tort remedies in employment actions has potential for enormous consequence in the stability of the business community); Scott v. Pacific Gas & Elec. 1997Leasing Int'l, Inc., 183 Ariz. 550 , 905 P.2d 559 (1995) (a public policy tort for failure to promote does not exist and it is unnecessary for courts to create one); Foley v. Interactive Data Corp., 47 Cal.3d 654 , 254 Cal.Rptr. 211 , 765 P.2d 373 (1988) (expansion of tort remedies in employment actions has potential for enormous consequence in the stability of the business community); Scott v. Pacific Gas & Elec. | 2 | 1997–1997 |
Pamela Ludwig v. C & a Wallcoverings, Incorporated, an Ohio Corporation D/B/A Kinney Wallcoverings
green
2 sentences1997See, e.g., Zimmerman v. Buchheit of Sparta, Inc., 164 Ill.2d 29 , 206 Ill.Dec. 625 , 645 N.E.2d 877 (1994) (refusing to extend the tort of wrongful discharge to include demotions); Ludwig v. C & A Wallcoverings, Inc., 960 F.2d 40 (7th Cir.1992) (employee cannot bring a wrongful discharge claim for retaliatory discharge when she was merely demoted); Mintz v. Bell Atlantic Sys. 1997See, e.g., Zimmerman v. Buchheit of Sparta, Inc., 164 Ill. 2d 29 , 645 N.E.2d 877 (1994) (refusing to extend the tort of wrongful discharge to include demotions); Ludwig v. C & A Wallcoverings, Inc., 960 F.2d 40 (7th Cir. 1992) (employee cannot bring a wrongful discharge claim for retaliatory discharge when she was merely demoted); Mintz v. Bell Atlantic Sys. | 2 | 1997–1997 |
Martin v. Gonzaga Univ.
green
2 sentences2024Martin v. Gonzaga Univ., 191 Wn.2d 712, 723 , 425 P.3d 837 (2018) (citing HENRY H. 2024Martin v. Gonzaga Univ., 191 Wn.2d 712, 723 , 425 P.3d 837 (2018) (citing HENRY H. | 1 | 2024–2024 |
McNabb v. Department of Corrections
green
1 sentence2024The former employees derived this policy from (1) article I, section 7 of the Washington State Constitution, (2) McNabb v. Department of Corrections, 163 Wn.2d 393 , 180 P.3d 1257 (2008), and (3) RCW 70.122.010. 1 Consolidated Omnibus Budget Reconciliation Act of 1985, PL 99-272. 5 No. 39615-1-III Adams v. Confluence Health With respect to their WLAD claim, the former employees asserted both disparate treatment and failure to accommodate. | 1 | 2024–2024 |
McNabb v. Department of Corrections
green
1 sentence2024The former employees derived this policy from (1) article I, section 7 of the Washington State Constitution, (2) McNabb v. Department of Corrections, 163 Wn.2d 393 , 180 P.3d 1257 (2008), and (3) RCW 70.122.010. 1 Consolidated Omnibus Budget Reconciliation Act of 1985, PL 99-272. 5 No. 39615-1-III Adams v. Confluence Health With respect to their WLAD claim, the former employees asserted both disparate treatment and failure to accommodate. | 1 | 2024–2024 |
| Sedlacek v. Hillis green | 1 | 2021–2021 |
| Dicomes v. State green | 1 | 2019–2019 |
| Kimball v. Public Utility District No. 1 green | 1 | 2017–2017 |
| Rose v. Anderson Hay & Grain Co. green | 1 | 2017–2017 |
| General Dynamics Corp. v. Superior Court green | 1 | 2017–2017 |
| Domingo v. Boeing Employees' Credit Union green | 1 | 2015–2015 |
| Cudney v. ALSCO, Inc. green | 1 | 2014–2014 |
| State v. Cauthron green | 1 | 2011–2011 |
| Ellis v. City of Seattle green | 1 | 2011–2011 |
| State v. Copeland green | 1 | 2011–2011 |
| Danny v. Laidlaw Transit Services, Inc. green | 1 | 2011–2011 |
| State v. Copeland green | 1 | 2011–2011 |
| Danny v. Laidlaw Transit Services, Inc. green | 1 | 2011–2011 |
| Christensen v. Grant County Hosp. Dist. green | 1 | 2008–2008 |
| Ellis v. City of Seattle neutral | 1 | 2001–2001 |
| Smith v. Bates Technical College green | 1 | 2000–2000 |
| Griffin v. Eller green | 1 | 2000–2000 |
| Cagle v. Burns and Roe, Inc. green | 1 | 1991–1991 |
| Frampton v. Central Indiana Gas Company green | 1 | 1991–1991 |
| Hunsley v. Giard green | 1 | 1991–1991 |
| Brady v. Daily World green | 1 | 1990–1990 |
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.
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.