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Keywords

contractlawsuitappealtrialmotionwillcompliancebad faith
contracttortliabilitytrialmotionsummary judgmentwillcase lawappellantmotion for summary judgment

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Thompson v. St. Regis Paper Co., 102 Wash.2d 219, 685 P.2d 1081, 116 L.R.R.M. (BNA) 3142, 105 Lab.Cas. P 55,616, 1 IER Cases 392

Facts

Kenneth L. Thompson began working for St. Regis Paper Company in 1963 and was promoted to a management position by 1973. Despite receiving merit raises and bonuses, he was asked to resign in January 1980 after 17 years of service, with the only reason given being that he 'stepped on somebody's toes.' Following his termination, St. Regis refused to provide further justification, and Thompson alleged that the company acted dishonestly and in bad faith. He filed a lawsuit after his motion to compel the employer to answer interrogatories was denied.

The appellant, Kenneth L. Thompson, began working for St. Regis Paper Company (hereinafter St. Regis) in 1963. There is no written agreement concerning his employment. In 1973 he was promoted into a management position, reaching the rank of divisional controller for the Distribution Yards and Industrial Supply Division of St. Regis in Tacoma, Washington. From 1973 through 1979 he received regular bonuses under the Management Incentive Compensation Plan. Throughout this period the appellant received no complaints or criticism from his superiors concerning his work. In December 1979, he received a merit pay raise.

Issue

Does a terminable-at-will employee have a cause of action for wrongful discharge when his employer summarily discharges him and gives no reason for so doing?

Does a terminable at will employee have a cause of action for wrongful discharge when his employer summarily discharges him and gives no reason for so doing?

Rule

An employment contract indefinite as to duration is terminable at will by either the employee or employer, but such a contract is terminable by the employer only for cause if there is an expressed or implied agreement to that effect or if the employee gives consideration in addition to the contemplated service.

An employment contract indefinite as to duration, is terminable at will by either the employee or employer. But such a contract is terminable by the employer only for cause if (1) there is an expressed or implied agreement to that effect or (2) the employee gives consideration in addition to the contemplated service.

Analysis

The court analyzed whether the employee manual issued by St. Regis created any obligations regarding termination. It concluded that the manual's provisions could potentially create enforceable promises if they indicated specific treatment in specific situations. Additionally, the court recognized that if Thompson's discharge was related to his compliance with the Foreign Corrupt Practices Act, it could contravene public policy, thus allowing for a wrongful discharge claim.

The employment relationship at issue is, under our prior case law, terminable at will by either the employer or employee for any reason without either incurring liability. However, we noted that a number of states have carved out exceptions to the common-law rule and we implied that in the future we might also modify the employment at will doctrine.

Conclusion

The Supreme Court reversed the trial court's decision, holding that material questions of fact existed regarding the implications of the employee manual and the potential public policy violation. The case was remanded for further proceedings.

The trial court order granting St. Regis' pretrial motion for summary judgment is reversed. We also reverse the trial court's order denying appellant's motion to compel St. Regis to answer his interrogatories because the questions are relevant and may lead to admissible evidence.

Who won?

Kenneth L. Thompson prevailed in the appeal because the Supreme Court found that there were material issues of fact regarding the employer's obligations and potential public policy violations.

The Supreme Court, Brachtenbach, J., held that: (1) promises of specific treatment in specific situations found in employee manual or handbook issued by employer to employees may, in appropriate situations, obligate employer to act in accordance with those promises, and (2) employer may be liable in tort if employee is discharged for reason that contravenes a clear mandate of public policy.

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