Deanna Dicomes, Appellant v. the State of Washington, Respondents

Summary

The court affirmed summary judgment dismissing Deanna Dicomes's claims for wrongful discharge in violation of public policy, First Amendment retaliation, deprivation of a liberty interest without due process, and outrage. It held that her disclosure of budget information did not further a clear public policy because the agency's conduct was lawful and discretionary, and that her policymaking role and the need for loyalty and confidentiality outweighed her speech interest. The court also found no protected liberty interest because the discharge neither stigmatized her integrity nor foreclosed future employment, and no conduct sufficiently extreme to support outrage.