LaMar D. Havens, Petitioner v. C&D Plastics, Inc., Respondents

Summary

The Washington Supreme Court held that the trial court did not abuse its discretion in refusing a proposed jury instruction defining just cause for discharging a 'high-ranking' employee, because the unchallenged just-cause instruction let the employer argue its theory and the proposed instruction misstated the law by directing the jury to weight the employer's decision; it also held that the exclusion of the employee's diary entries, though based on untenable grounds, was harmless error. The court affirmed the Court of Appeals' reversal of the $363,958 promissory estoppel award because there was no clear and definite promise of permanent employment terminable only for just cause, and it upheld the dismissals of the public-policy wrongful discharge claim (no nexus to the Boeing certification requirements) and the negligent misrepresentation claim. The $65,901 breach-of-implied-one-year-contract award was affirmed, and the case was remanded solely for recalculation of the attorney fee award.