Snyder v. Medical Service Corp. of Eastern Washington

Snyder v. Medical Service Corp., 145 Wash. 2d 233 (2001) · Supreme Court of Washington · December 13, 2001

Summary

The Washington Supreme Court affirmed summary dismissal of Michelle Snyder’s claims against her former employer for constructive discharge, disability discrimination based on failure to accommodate, outrage, and negligent infliction of emotional distress. The court held that Washington recognizes wrongful discharge rather than a standalone constructive-discharge claim, that the employer had no duty to accommodate a disability not disclosed before the relevant employment decisions, and that the alleged conduct did not support liability against the employer for the asserted tort claims.

Holdings

  1. Washington does not recognize constructive discharge as an independent cause of action; constructive discharge may be part of a wrongful-discharge claim, which requires a discharge contravening a clear mandate of public policy. Because Snyder did not allege that her constructive discharge violated a recognized public policy, dismissal was proper.
  2. An employer's duty to reasonably accommodate a disability does not arise until the employer is made aware of the disability. Because Snyder did not inform MSC of her alleged disability until after her prior transfer requests had been denied, those denials could not support a failure-to-accommodate claim. In addition, WLAD does not require an employer to accommodate a disability by providing a new supervisor.
  3. MSC was not liable as a matter of law for Hall's intentional tortious conduct because Hall acted outside the scope of her employment and MSC prohibited supervisors from using physical force or threats of physical force. Snyder's outrage claim against MSC was therefore properly dismissed.
  4. Absent a statutory or public-policy mandate, an employer does not owe employees a duty to use reasonable care to avoid the inadvertent infliction of emotional distress when responding to workplace disputes. Because Snyder identified no applicable duty and her claim concerned a workplace dispute or personality difference, dismissal was proper.

Questions Presented

  1. Whether Washington recognizes constructive discharge as an independent cause of action.
  2. Whether MSC had a duty under Washington's Law Against Discrimination to accommodate Snyder's alleged mental disability before Snyder informed MSC of the disability, including by providing a new supervisor or transferring her.
  3. Whether Snyder presented a prima facie claim for the tort of outrage against MSC based on Hall's conduct.
  4. Whether Snyder presented a cognizable claim for negligent infliction of emotional distress based on MSC's handling of workplace disputes.

Disposition

affirmed

Cases Cited (36)

  • Riccobono v. Pierce County, 92 Wn. App. 254, 966 P.2d 327 (1998)(followed)
  • Roberts v. Atlantic Richfield Co., 88 Wn.2d 887, 568 P.2d 764 (1977)(followed)
  • Webster v. Schauble, 65 Wn.2d 849, 400 P.2d 292 (1965)(followed)
  • Roberts v. Dudley, 140 Wn.2d 58, 993 P.2d 901 (2000)(followed)
  • Thompson v. St. Regis Paper Co., 102 Wn.2d 219, 685 P.2d 1081 (1984)(followed)
  • Jane Doe v. Boeing Co., 121 Wn.2d 8, 846 P.2d 531 (1993)(followed)
  • Pulcino v. Federal Express Corp., 141 Wn.2d 629, 9 P.3d 787 (2000)(followed)
  • Goodman v. Boeing Co., 127 Wn.2d 401, 899 P.2d 1265 (1995)(followed)
  • Holland v. Boeing Co., 90 Wn.2d 384, 583 P.2d 621 (1978)(followed)
  • Dean v. Municipal of Metropolitan Seattle, 104 Wn.2d 627, 708 P.2d 393 (1985)(followed)

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