Payne v. Sunnyside Community Hospital
Washington Court of Appeals
894 P.2d 1379 (1995)
After 13 years at Sunnyside Community Hospital (defendant), Sharon Payne (plaintiff) was summarily fired without the progressive-discipline steps her employee handbook described as mandatory, even though the handbook's front page disclaimed any binding effect and preserved at-will employment; in her own role disciplining other employees, Payne had repeatedly been instructed by hospital administrators to follow progressive discipline, and the personnel director stated managers were expected to follow those procedures generally. Payne sued for wrongful discharge, and the trial court granted Sunnyside summary judgment, finding no material factual dispute about whether the at-will disclaimer remained valid despite the parties' disagreement over whether hospital records showed a consistent pattern of following progressive discipline in other terminations; Payne appealed.
Whether a conspicuous handbook disclaimer preserving at-will employment can be negated by the handbook's own mandatory disciplinary language and the employer's practice of instructing managers to follow that language, creating a jury question rather than being resolved on summary judgment.