Justia Washington Supreme Court Opinion Summaries

Petitioner Ian Dean worked aboard a fishing vessel owned by The Fishing Company of Alaska (FCA). While aboard the vessel, Dean experienced pain in his hands and neck. After Dean left the vessel, he sought medical treatment and FCA began paying Dean maintenance and cure as required by general maritime law. After paying Dean's maintenance and cure for just over three years, FCA stopped paying when it obtained the opinion of a physician that Dean's injuries had reached maximum cure. At the time when FCA cut off Dean's maintenance and cure, Dean's own physician opined that Dean's injuries could benefit from additional treatment. Dean sued FCA and filed a motion asking the trial court to order FCA to resume paying maintenance and cure. The trial court applied a summary judgment standard to Dean's motion and denied the motion. The Court of Appeals affirmed. Upon review, the Supreme Court disagreed with the trial court's decision to apply the summary judgment standard and reversed. View "Dean v. Fishing Co. of Alaska" on Justia Law

While employed as a physician at Quincy Valley Medical Center (QVMC), Gaston Cornu-Labat was the subject of several complaints that raised doubts as to his competency to practice medicine. QVMC conducted two investigations that ended after the charges against Dr. Cornu-Labat were not substantiated. Nevertheless, QVMC requested that Dr. Comu-Labat be psychologically evaluated and ended the doctor's employment when he failed to consult the recommended provider. Dr. Cornu-Labat filed a Public Records Act (PRA) request asking for records related to the hospital's investigations. QVMC claimed the documents were exempt from disclosure. The trial court granted summary judgment in favor of Dr. Cornu-Labat, holding none of the PRA exemptions invoked by QVMC applied. The court concluded that the records of a peer review committee that contained nonphysicians could not qualify for the exemption. Upon review, the Supreme Court determined that was error. The Court remanded because questions of material fact remained as to whether the records at issue were prepared for a regularly constituted peer review body. Further, questions remained as to whether any records were generated during a confidential meeting of agents of the QVMC board concerning Dr. Cornu-Labat's clinical or staff privileges. View "Cornu-Labat v. Hosp. Dist. No. 2 of Grant County" on Justia Law

Respondent Robert Chaney was fired from his position and argued his termination violated the federal Family and Medical Leave Act of 1993 (FMLA). The employer, Providence Health Care d/b/a Sacred Heart Medical Center & Children's Hospital (Providence), claimed no violation of the FMLA occurred. The trial court denied motions for a directed verdict on the issue by both Chaney and Providence. Based upon undisputed facts, the Supreme Court held that the trial court erred in failing to grant Chaney's motion for a directed verdict that as a matter of law the hospital violated the FMLA. In 2005, his wife fell ill after giving birth, Chaney himself suffered a back injury, and he relied heavily on FMLA leave over the next two years. By June 2007, Chaney had used up most of his FMLA leave and had been donated leave from other employees. The record indicated that Providence administration and other staff were growing resentful that Chaney had taken so much time off. In 2007, an employee reported that Chaney appeared fatigued and incoherent. Although no claim was made that his work was compromised, Chaney was ordered to report for drug testing. The drug test was positive for methadone. Chaney had a prescription for methadone to treat back pain, but the doctor who gave the drug test noted that Chaney "[m]ay need fitness for duty evaluation or visit to his Dr. to fine tune his medication." A few months later, Chaney indicated he was prepared to return to work. The record reflected that Chaney was erroneously informed he needed Providence's permission to return to work. This violated the FMLA, under which Chaney could only be required to get authorization from his own health care provider. Chaney went to Providence's doctor, and administration told him the hospital would not allow him to return to work unless their doctor changed his recommended restriction. The hospital's doctor refused to change his recommendation. Subsequently, Chaney was fired. Providence claimed the termination was proper because Chaney failed to provide a valid fitness for work certification as required under the FMLA. View "Chaney v. Providence Health Care" on Justia Law

The issue before the Supreme Court in this case concerned an arbitration award arising out of a collective bargaining agreement. The arbitration award in this case reinstated Port of Seattle (Port) employee Mark Cann with a 20-day unpaid suspension after he was terminated for hanging a noose in the workplace for nonracial reasons. The reviewing trial court found this punishment so lenient that it violated the public policy against racial harassment in the workplace and imposed a six-month unpaid suspension instead. The arbitrator found that Cann intended the noose as a joke toward an older white co-worker. The arbitrator determined that Cann's impression of a noose was "not racial" and that in this situation, Cann was "more clueless than racist." The arbitrator also noted that the white employee targeted by the "joke" was not offended, and an African-American employee who observed the noose was angry but did not feel harassed. In light of these facts, the arbitrator determined that a 20-day unpaid suspension was the appropriate discipline. Given that Cann's 20-working-day unpaid suspension amounts to a month without pay, and given that so many working families live month to month, the Supreme Court found that to be a substantial penalty. "As we are bound by the arbitrator's findings of fact, we cannot find that a 20-day suspension was insufficient to deter such conduct in the future. Therefore, we reverse the trial court's decision to vacate the arbitrator's award. We also take this opportunity to clarify that a trial court that properly vacates an arbitration award does not have authority to impose its own remedy. Instead, trial courts facing such a situation should remand for further proceedings." View "Int'l Union of Operating Eng'rs, Local 286 v. Port of Seattle" on Justia Law

Brandon Afoa was paralyzed in an accident while he was working at Sea-Tac Airport and sought to recover from the Port of Seattle on three theories the Supreme Court applied in other multiemployer workplace cases: as a business invitee; for breach of safety regulations under the Washington Industrial Safety and Health Act of 1973 (WISHA); and the duty of a general contractor to maintain a safe common area for any employee of subcontractors. The Court concluded that the same principles that apply to other multiemployer workplaces apply to Sea-Tac and that a jury could find the Port (which owns and operates the airport) liable under any of these three theories. The Court affirmed the Court of Appeals, which reversed the trial court’s summary judgment dismissing Afoa's claims, and remanded the case for further proceedings. View "Afoa v. Port of Seattle" on Justia Law

Washington State Nurses Association (WSNA) sought overtime pay pursuant to the Minimum Wage Act (MWA) for work performed by the approximately 1,200 registered nurses employed by Sacred Heart Medical Center in Spokane. Sacred Heart was obligated by its collective bargaining agreement (CBA) with WSNA to provide its nurses with a paid 15 minute block rest period each four hour work period. The parties did not dispute that when a rest period was missed, Sacred Heart provided the nurses with the equivalent of 30 minutes of straight time compensation: the 15 minutes they would have received had they merely rested as well as 15 additional minutes for instead working during the period. Relying on a Washington industrial welfare regulation requiring a 10 minute rest period on the employer's time for every four hours worked, the nurses claimed they were entitled to overtime pay, not just the straight pay they already received, for 10 of the 15 minutes of each rest period they missed. The issue before the Supreme Court hinged on how "hours worked" are calculated: whether the 15 minutes nurses spent working through their breaks should be added to or substituted for the 15 minutes they would have spent at rest. The Court held that both the missed opportunity to rest and the additional labor nurses provide constitute "hours worked." Even though Sacred Heart did not require the nurses to physically remain at the hospital after the end of the workday to make up their rest periods, nurses were entitled to overtime compensation because they provided additional labor to Sacred Heart. View "Wash. State Nurses Ass'n v. Sacred Heart Med. Ctr." on Justia Law

An employee of a church who claimed she was harmed by actions of a church's minister brought numerous claims against the church and the minister. At this point in the proceedings, the case involved her negligent retention, negligent supervision, and Title VII sex discrimination claims against the church. The Court of Appeals, reversing the trial court's grant of partial summary judgment, ruled that these claims were not barred by the First Amendment to the United States Constitution as the trial court had determined. Upon review of the matter, the Supreme Court reversed the Court of Appeals and reinstated the trial court's grant of summary judgment on the negligent retention and supervision claims. "Under the First Amendment, allowing these claims to go forward would violate the First Amendment right of the church to select and supervise its ministers as well as the First Amendment right of a hierarchical religious organization to be free of government involvement in the decisions made by its ecclesiastical tribunals. We remand the Title VII claims for further proceedings." View "Erdman v. Chapel Hill Presbyterian Church" on Justia Law

Three certified questions came before the court from the Ninth Circuit Court of Appeals concerning application of the farm labor contractors act (FLCA), chapter 19.30 RCW. The primary question asked whether a trial court, if awarding statutory damages under the civil remedies provision of the FLCA must award $500 per plaintiff per violation. Upon review, the Washington Supreme Court answered in the affirmative. The second question asked whether requiring a trial court to award $500 per plaintiff per violation violated due process or public policy; the Court answered in the negative, expressly limiting its analysis and holding on this question to state due process principles and statutes. The third question asked whether the FLCA provided for awarding statutory damages to persons who have not been shown to have been aggrieved by a particular violation. "Because our standing jurisprudence tracks that of the United States Supreme Court, we leave to the Ninth Circuit to answer this question based on its standing jurisprudence and the standing jurisprudence of the Supreme Court." View "Perez-Farias v. Global Horizons, Inc." on Justia Law

This case concerned the classification of workers as employees or independent contractors for purposes of the Washington Minimum Wage Act (MWA). A class of 320 former and current FedEx Ground Package System, Inc. (FedEx) delivery drivers (hereinafter Anfinson) filed suit seeking overtime wages under the MWA and reimbursement for uniform expenses under the industrial welfare act (IWA). The dispute with respect to both claims was whether the drivers were employees or independent contractors. The parties disagreed on the correct test to distinguish these categories under the MWA; FedEx argued that the common law right-to-control standard governs while Anfinson contended that the federal Fair Labor Standards Act of 1938 (FLSA) economic-dependence test controls. The trial court gave the jury a hybrid instruction, focusing the inquiry on FedEx's right to control in light of the economic-dependence factors. The jury determined that the drivers were independent contractors. Anfinson appealed, contending, among other things, that the jury instructions misinformed the jury about the standards for determining worker status and about the requirement that class status and evidence be "common to the class members." The Court of Appeals held that the jury instruction defining the standard for determining worker status was erroneous and prejudicial and reversed. The Court of Appeals further held that the jury instruction on the burden of proof was erroneous because it misled the jury and was prejudicial. Upon review, the Supreme Court affirmed the Court of Appeals in both respects. View "Anfinson v. FedEx Ground Package Sys., Inc." on Justia Law

Respondent Bonnie Anthis won a civil suit against Petitioner Walter Copland for the wrongful death of her husband, Harvey Anthis. Respondent sought to collect Petitioner's only known asset, his retirement pension, to satisfy the judgment. Petitioner, a retired police officer, argued that his Law Enforcement Officers' and Firefighters' Retirement System (LEOFF) pension money could not be garnished even after it has been deposited into his personal bank account. The trial court disagreed and ruled that the money in the account could be garnished. Petitioner appealed, and the Court of Appeals certified the question to the Supreme Court. Upon review, the Supreme Court affirmed the trial court: Washington has one statute that exempts a beneficiary's money "whether [it] be in the actual possession of such person or be deposited or loaned." Other exemption statutes exempt only "[t]he right . . . to a . . .retirement allowance." The survey of case law and the plain language in the LEOFF exemption statutes indicate that the latter statutes exempt funds before they are given into the hands of the beneficiary, but not after receipt. View "Anthis v. Copland" on Justia Law