Richard Grimwood, Petitioner v. University of Puget Sound, Inc., Respondent (Washington 1988)

Summary

The court affirmed summary judgment against an employee's age-discrimination, implied-contract, and wrongful-discharge claims. The employee offered only conclusory opinions and deposition testimony rather than admissible facts showing that the employer's documented performance-based reasons were pretextual, and the employer had complied with its personnel-manual policies. The wrongful-discharge claim failed because it depended on the unsuccessful discrimination claim, while the court expressly left broader public-policy questions undecided.

Holding

Age discrimination. Summary judgment was proper because, even assuming Grimwood established a prima facie case, the University articulated legitimate, nondiscriminatory reasons for the discharge and Grimwood failed to produce admissible evidence creating a genuine issue that those reasons were pretextual.

Breach of employment contract. Summary judgment was proper because there was no express contract for continued employment, Grimwood identified no factual basis for an implied promise beyond his personal expectations, and the University complied with the applicable personnel-manual policies.

Wrongful discharge in violation of public policy. The wrongful-discharge claim failed because it was based on the alleged statutory age discrimination, which had not been established.

Richard Grimwood, Petitioner v. University of Puget Sound, Inc., Respondent

Summary

Holding

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