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Keywords

lawsuitappealtrialmotion
appealtrialverdictmotionsummary judgmentmotion for summary judgmentmotion for directed verdict

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Bishop v. State, 77 Wash.App. 228, 889 P.2d 959

Facts

Phyllis Bishop began working in the mailroom of the Washington State Penitentiary in 1984. In November 1989, she reported suspected theft of money from inmate mail to her supervisor and other officials, leading to an investigation. Following her report, Bishop experienced a change in her supervisor's behavior, which she claimed included hostility and unfair treatment. In October 1990, she filed a lawsuit against the Department of Corrections and her supervisor, alleging several claims including negligent infliction of emotional distress. The case proceeded to trial, where the jury found the Department of Corrections 67% negligent.

Ms. Bishop began working in the mailroom in 1984. Sergeant Vera Roop was her supervisor from 1986 until February 1991. In November 1989, Ms. Bishop became aware of circumstances that led her to believe another employee was stealing money from inmate mail. On the day she reported her concerns, Sergeant Roop was not at work. Ms. Bishop reported the incident to Officer Erdman and to Sergeant Roop's supervisor, Captain Morgan. She later spoke with the superintendent of the penitentiary. An investigation ensued and a series of meetings took place.

Issue

Did the Washington State Department of Corrections owe a duty to Phyllis Bishop to avoid the negligent infliction of emotional distress in response to workplace disputes?

Did the Washington State Department of Corrections owe a duty to Phyllis Bishop to avoid the negligent infliction of emotional distress in response to workplace disputes?

Rule

Absent a statutory or public policy mandate, employers do not owe employees a duty to use reasonable care to avoid the inadvertent infliction of emotional distress when responding to workplace disputes.

Absent a statutory or public policy mandate, employers do not owe employees a duty to use reasonable care to avoid the inadvertent infliction of emotional distress when responding to workplace disputes.

Analysis

The court analyzed the nature of the workplace disputes and determined that the conduct in question did not rise to the level of being unreasonably dangerous. It emphasized that the utility of allowing employers to manage workplace conflicts outweighed the potential emotional distress that employees might experience. The court concluded that the existing legal framework did not support Bishop's claim for negligent infliction of emotional distress under the circumstances presented.

The court analyzed the nature of the workplace disputes and determined that the conduct in question did not rise to the level of being unreasonably dangerous. It emphasized that the utility of allowing employers to manage workplace conflicts outweighed the potential emotional distress that employees might experience.

Conclusion

The Court of Appeals reversed the trial court's judgment in favor of Bishop and dismissed her claim for negligent infliction of emotional distress.

The Court of Appeals reversed the trial court's judgment in favor of Bishop and dismissed her claim for negligent infliction of emotional distress.

Who won?

Washington State Department of Corrections prevailed in the appeal because the court found that they did not owe a duty to avoid inflicting emotional distress in the context of workplace disputes.

DOC contends the trial court erred in denying its motion for summary judgment dismissing Ms. Bishop's claim for negligent infliction of emotional distress and in denying its motion for directed verdict.

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