Charles Hause v. Spokane County

CourtCourt of Appeals of Washington
DecidedJuly 25, 2024
Docket39659-2
StatusUnpublished

This text of Charles Hause v. Spokane County (Charles Hause v. Spokane County) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charles Hause v. Spokane County, (Wash. Ct. App. 2024).

Opinion

FILED July 25, 2024 In the Office of the Clerk of Court WA State Court of Appeals Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

CHARLES HAUSE, an individual, ) ) No. 39659-2-III Petitioner, ) ) v. ) ) SPOKANE COUNTY, a Washington ) UNPUBLISHED OPINION Municipal Corporation, ) ) Respondent. )

FEARING, J. — Charles Hause sues his former employer, Spokane County, for

wrongful termination of his employment under numerous causes of action. The Spokane

County sheriff fired Hause after Hause filed a workplace violence complaint and the

sheriff concluded that Hause misrepresented facts during the investigation of his

complaint. We affirm the superior court’s summary judgment dismissal of Hause’s

causes of action.

FACTS

We take the facts from affidavits filed in support of and in opposition to the

defendant Spokane County’s summary judgment motion. Although we narrate some of

Spokane County’s evidence, we view the facts in a light favorable to nonmoving party,

Charles Hause. No. 39659-2-III Hause v. Spokane County

In January 2012, Spokane County hired Charles Hause as a forensic technician in

the Spokane County Sheriff’s Office. He processed latent fingerprints. In June of 2016,

Hause was promoted to forensic specialist. Hause garnered a positive employment

record and, in 2020, then-Sheriff Ozzie Knezovich awarded him a Medal of Merit.

During the time of Charles Hause’s employment with the Spokane County

Sheriff’s Office, the county maintained employment policies compiled in the Spokane

County Personnel Policy Manual. The manual applied to sheriff department employees,

among other employees.

We quote some of the sections of the Spokane County Personnel Policy Manual

important to Charles Hause’s suit. Section 450 of the Personnel Policy Manual addressed

protecting employees from retaliation for whistleblowing. The section sought to:

encourage reporting by [the county’s] employees and/or officers of improper governmental action taken by Spokane County officers or employees, and protect County employees and/or officers who have reported improper governmental actions in accordance with applicable laws.

Clerk’s Papers (CP) at 521 (underlining omitted). Section 450 defined “improper

governmental action” as:

1. “Improper governmental action” means any action by a Spokane County officer or employee: a. That is undertaken in the performance of the officer’s or employee’s official duties, whether or not the action is within the scope of the employee’s employment; and

2 No. 39659-2-III Hause v. Spokane County

b. That (i) is in violation of any federal, state, or local law or rule, (ii) is an abuse of authority, (iii) is of substantial and specific danger to the public health or safety or (iv) is a gross waste of public funds. “Improper governmental action” does not include personnel actions, including employee grievances, complaints, appointments, promotions, transfers, assignments, reassignments, reinstatements, restorations, reemployment, performance evaluations, reductions in pay, dismissal, suspensions, demotions, violations or collective bargaining or civil service laws, alleged violations of labor agreements or reprimands or actions taken pursuant to those statutory provision enumerated in RCW 42.4l .020(l)(b).

CP at 522. The same section also outlined the procedure for reporting improper

governmental conduct:

Procedures for Reporting Spokane County employees, who become aware of improper governmental actions, whether within their office or another County office, should raise the issue first with their immediate supervisor. The immediate supervisor for any County employee hired or appointed by an elected official, other than the Board of County Commissioners or any of its department heads, shall be the elected official hiring or appointing the employee. The immediate supervisor for those employees hired by the Board of County Commissioners or any department head, shall be the department head of the office in which they are employed. For the purpose of this policy, a department head shall be defined as a person in charge of a major administrative division of County government under the direct control of the Board of County Commissioners, who reports directly to the County Administrative Officer. The employee shall submit a written report to the supervisor, or to a person designated by the supervisor, stating in detail the basis for the employee’s belief that an improper governmental action has occurred. Where the employee reasonably believes the improper governmental action involves his or her immediate supervisor, the employee may raise the issue directly with the County Administrative Officer or such other person as may be designated by the County Administrative Office to receive reports of improper governmental action. Where the employee reasonably believes the improper governmental action involves the County Administrative Officer, the employee may raise the issue directly with the chairman of the

3 No. 39659-2-III Hause v. Spokane County

Board of County Commissioners. Where the employee reasonably believes the improper governmental action involves a Spokane County Commissioner, the employee may raise the issue directly with the Spokane County Prosecuting Attorney. .... Spokane County employees who fail to make a good faith attempt to follow the County’s procedures in reporting improper governmental action shall not receive the protection provided by the County in these procedures.

CP at 523-24. The following subsection of Section 450 of the Spokane County Personnel

Policy Manual identified whistleblower protections for county employees:

Protection Against Retaliatory Actions Spokane County Elected Officials and employees are prohibited from taking retaliatory action against a County employee because he or she has in good faith reported an improper governmental action in accordance with these policies and procedures. Employees who believe that they have been retaliated against for reporting an improper governmental action should advise their immediate supervisor, the Human Resources Director, or his/her designee. The immediate supervisor or Human Resources Director shall take appropriate action to investigate and address complaints of retaliation.

CP at 524.

Section 605 of the Personnel Policy Manual housed the county’s Workplace

Violence Prevention Program. Subsection VI-D of Section 605 directed employees to

report known or suspected incidents of workplace violence. Elsewhere in the manual the

prevention program defined “workplace violence” as:

any behavior that is violent, threatens violence, coerces, harasses, intimidates others, interferes with an individual’s legal rights of movement or expression, or disrupts the workplace of the [c]ounty’s ability to provide services to the public.

4 No. 39659-2-III Hause v. Spokane County

CP at 512. One example given of workplace violence was the throwing of objects. CP

513. Subsection VII A I of Section 605 declared:

Workplace violence, threats of workplace violence, or observations of workplace violence shall be reported· immediately to the employee’s immediate supervisor and the Risk Management Department. A WVPP Incident Report Form shall be submitted to Risk Management.

CP at 244.

The Spokane County Sheriff’s Office kept its own Policy Manual. An

unnumbered opening section of the manual announced the expectation that a department

employee refrain from

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Charles Hause v. Spokane County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charles-hause-v-spokane-county-washctapp-2024.