Summary
The Washington Supreme Court held that former RCW 4.96.020 did not apply to claims against individual government employees. It also held that the statute did not apply to federal civil rights claims under 42 U.S.C. § 1983 or unfair labor practice claims under chapter 41.56 RCW. The court reversed the Court of Appeals and remanded for consideration of other issues.
Topics
Practice areas
Questions Presented
- Whether former RCW 4.96.020 applied to claims against individual government employees.
- Whether former RCW 4.96.020 applied to claims under 42 U.S.C. § 1983.
- Whether unfair-labor-practice claims under chapter 41.56 RCW were tort claims subject to former RCW 4.96.020.
- Whether the Court of Appeals erred in treating the relevant holding in Bosteder v. City of Renton as a nonbinding plurality decision.
Holdings
- Former RCW 4.96.020 did not apply to claims against government employees sued in their individual capacities.
- Former RCW 4.96.020 did not apply to claims under 42 U.S.C. § 1983.
- Unfair-labor-practice claims under chapter 41.56 RCW are not tort claims for damages and therefore are not subject to former RCW 4.96.020.
Key quotations
“A majority of this court thus concluded that former RCW 4.96.020 does not apply to claims against individuals.” (571)
“Unfair labor practice claims under chapter 41.56 RCW are not tort claims for damages and are thus not subject to the claims filing statute.” (572)
Factual background
Charlotte Wright and the Public School Employees of Evergreen sued school-district officials and the district based on alleged mistreatment of employees, asserting tort, federal civil-rights, unfair-labor-practice, negligent-supervision, and public-disclosure claims. Wright and the union later amended the complaint to add David Larson and additional tort claims against Jim Terrell individually. The defendants argued that the tort claims were barred because the plaintiffs had not first filed them with the district under former RCW 4.96.020.
Procedural history
The trial court dismissed claims against individual government employees and federal civil-rights claims based on failure to file claims with the school district under former RCW 4.96.020, denied a motion to compel discovery, and later issued additional rulings concerning the dismissed claims. The Court of Appeals affirmed the dismissals. The Washington Supreme Court granted review, reversed, and remanded to the Court of Appeals to consider other grounds for affirmance raised on appeal.
Remand instructions
The case was remanded to the Court of Appeals to consider the other issues raised on appeal and any other grounds for affirming the dismissal.