Payne v. Sunnyside Community Hospital
Washington Court of Appeals
894 P.2d 1379 (1995)
Sharon Payne (plaintiff) worked for Sunnyside Community Hospital (Sunnyside) (defendant) for 13 years before being summarily fired. Sunnyside’s employee handbook stated that Sunnyside had an “obligation” to keep qualified employees and set forth progressive discipline “steps to be followed.” The handbook also stated that the progressive discipline procedures could only be changed by the CEO in writing. Nevertheless, the first page of Sunnyside’s handbook had a disclaimer saying that Sunnyside had “sole discretion” whether to follow the handbook, and the handbook did not alter the at-will employment relationship between Sunnyside and its employees. In her role as business-office manager, Payne sometimes had to discipline other Sunnyside employees. Whenever situations calling for discipline arose, Payne was instructed by Sunnyside’s personnel director or assistant administrator to follow progressive discipline. Sunnyside’s personnel director also later said that managers were expected to follow the handbook’s progressive-discipline procedures. However, in Payne’s own case, Sunnyside did not follow the progressive procedures before firing Payne. After Payne was fired, Payne sued Sunnyside for wrongful discharge, contending Sunnyside had violated the handbook’s progressive-discipline procedures. Sunnyside filed a motion for summary judgment, arguing that Payne was an at-will employee who could be fired at any time. The trial court acknowledged that, under Washington law, an at-will disclaimer like the one in the handbook may be negated by contrary actions. The parties disagreed whether the records of other terminated employees did or did not show Sunnyside had a pattern of using the handbook’s progressive-discipline procedures. The trial court dismissed Payne’s case as not having raised an issue of material fact regarding the validity of the handbook’s at-will disclaimer. Payne appealed.
Rule of Law
Holding and Reasoning (Thompson, C.J.)
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