Jessica Tuffley v. Employment Security Department

CourtCourt of Appeals of Washington
DecidedNovember 20, 2024
Docket40134-1
StatusUnpublished

This text of Jessica Tuffley v. Employment Security Department (Jessica Tuffley v. Employment Security Department) 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
Jessica Tuffley v. Employment Security Department, (Wash. Ct. App. 2024).

Opinion

FILED NOVEMBER 20, 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

JESSICA TUFFLEY, ) No. 40134-1-III ) Petitioner, ) ) v. ) ) UNPUBLISHED OPINION STATE OF WASHINGTON, ) EMPLOYMENT SECURITY ) DEPARTMENT, ) ) Respondent. )

PENNELL, J. — Jessica Tuffley seeks judicial review of an administrative decision,

denying her request for unemployment benefits. We affirm.

FACTS AND PROCEDURAL HISTORY

Jessica Tuffley began working for Starbucks in 2019 as a senior manager in

partner communications. Over the course of her employment, the scope of Ms. Tuffley’s

work evolved. Ms. Tuffley’s job grew from brand campaigns, such as working on

Starbucks 50th anniversary, to topics such as “diversity, mental health, and policy work.”

Administrative Record (AR) at 74. Ms. Tuffley felt she lacked background and

experience in these new areas of responsibility. She worked over 60 hours a week in an

effort to meet the demands of her work, but her “mental health declined.” Id. at 75-76.

Ms. Tuffley advised her supervisor, Alisha Damodaran, about her struggles and

Ms. Damodaran decided to place Ms. Tuffley on a performance improvement plan No. 40134-1-III Tuffley v. Emp. Sec. Dep’t

(PIP). According to Ms. Tuffley, Ms. Damodaran told her that another employee had been

placed on a PIP and then was forced to leave the company. Ms. Tuffley came to believe

Ms. Damodaran wanted to use the PIP as a “tool” to fire her. Id. at 74-75. Ms. Tuffley

never met with Ms. Damodaran to discuss the details of the PIP.

In June 2021, Ms. Tuffley approached the human resources department at

Starbucks about taking a leave of absence. In an e-mail dated June 30, Ms. Tuffley

advised human resources her mental health was “suffering” and it seemed “directly

related to how much” she interacted with Ms. Damodaran. Id. at 91-92. Ms. Tuffley

indicated she had consulted with her therapist and they had decided a leave of absence

was her best option, and began the process of applying through the Employment Security

Department for paid family and medical leave.

On July 15, 2021, Ms. Tuffley’s therapist signed a “Certification of Serious Health

Condition Form,” describing Ms. Tuffley’s condition as “Post-traumatic stress disorder,

Major depressive disorder, [and] Anxiety disorder” with an expected duration of July 19,

2021, through October 11, 2021. Id. at 93. Adjacent to the dates of duration, there was an

option to specify whether the health condition was “chronic or permanent” rather than

subject to a duration. Id. Ms. Tuffley’s therapist did not select this alternative option.

2 No. 40134-1-III Tuffley v. Emp. Sec. Dep’t

The Department approved Ms. Tuffley’s application for paid leave benefits. The

leave term was set to begin on July 19, 2021, and end on October 16, 2021. Id. at 94.

In e-mail communications with Starbucks’ human resources department during the leave

application process, Ms. Tuffley was advised that when she returned to work from any

approved leave she would need to decide between participating in the PIP or accepting

an “exit package.” Id. at 91.

During the leave period, a separate human resources team at Starbucks conducted

an investigation of Ms. Tuffley’s claim that Ms. Damodaran had subjected her to a hostile

working environment. The company ultimately determined Ms. Tuffley’s claims against

Ms. Damodaran were “not substantiated.” Id. at 47.

Ms. Tuffley’s mental health improved during her leave of absence, but she did

not fully recover. While she was on leave, Ms. Tuffley claims she spoke to numerous

individuals about performing other roles within Starbucks. She also claims she applied

for at least one alternate position. However, the record lacks any specific information

about who Ms. Tuffley talked to or what options were sought.

Ms. Tuffley returned to work on October 21, 2021. At that point, she felt her job

conditions had not changed for the better. If anything, she believed things had gotten

worse because Ms. Damodaran’s supervisor, who she considered an ally, had left the

3 No. 40134-1-III Tuffley v. Emp. Sec. Dep’t

organization.

On October 25, 2021, Ms. Tuffley provided an oral notice of resignation to

Starbucks’ human resources manager Sara Meagher. As Ms. Meagher recalled,

Ms. Tuffley stated she was quitting because “[s]he did not [want] to go on the [PIP].”

Id. at 46. Ms. Meager was also aware Ms. Tuffley had mental health concerns and did

not want to continue in the fast-paced environment of her current position. Ms. Meager

surmised it was a “combination” of reasons that led to Ms. Tuffley’s decision, but

“ultimately” it was “the refusal to do the [PIP].” Id. at 47.

Ms. Tuffley’s last day with Starbucks was November 1, 2021. After her departure,

Ms. Tuffley applied for unemployment benefits with the Employment Security

Department.

In her original application for unemployment benefits, Ms. Tuffley stated she

had been “laid off.” Id. at 66. As further explanation, she stated as follows:

Over the course of the pandemic, the necessary subject matter knowledge of my role changed. Over the course of the summer, my work was redistributed and the team was restructured. My position was eliminated and is being replaced and they are looking for someone with that specific subject matter knowledge.

Id.

Starbucks responded to Ms. Tuffley’s application by stating she had “quit.”

4 No. 40134-1-III Tuffley v. Emp. Sec. Dep’t

Id. at 68. When asked why Ms. Tuffley quit, Starbucks responded she “quit rather than

complete a PIP.” Id. at 69.

After receiving different explanations for Ms. Tuffley’s separation from Starbucks,

the Department asked Ms. Tuffley for additional information. In response to the

Department’s request, Ms. Tuffley wrote as follows:

To clarify my original response, over the course of my employment, the scope of my job responsibilities evolved and grew from the general “long-term brand campaigns and agenda-setting announcements” work (ex: Starbucks 50th Anniversary) for which I was originally hired to include a heavy emphasis on specific topics that I have no background knowledge or experience in, including Starbucks inclusion and diversity, mental health, and policy work. My understanding is that my role focusing generally on brand campaigns was eliminated when I was separated (I was not separated because it was eliminated) and that Starbucks is replacing it with a position that specifically calls out expertise and background in these specific areas. This reinforces Starbucks need to have someone in role with expertise that I do not have.

Id. at 74.

In response to Starbucks’ claim that she quit rather than complete a PIP,

Ms. Tuffley provided the following statement:

My manager decided to put me on a performance improvement plan (PIP)—which I strongly disagreed with. Here are some of the primary reasons:

– I do not believe that my manager was putting me on the PIP in good-faith to improve my skills, but instead using the PIP as a tool to fire me. When my manager told me she was going to put me on a PIP she also told me that

5 No. 40134-1-III Tuffley v. Emp. Sec. Dep’t

she had put a peer on my team on a PIP before my peer was separated. This disclosure about my peer’s separation felt very threatening to me and reinforced my belief that my manager was not acting in good-faith.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re the Disciplinary Proceeding Against Denend
657 P.2d 1379 (Washington Supreme Court, 1983)
Verizon Northwest, Inc. v. Wash. Emp. SEC. Dept.
194 P.3d 255 (Washington Supreme Court, 2008)
Campbell v. Employment Security Department
180 Wash. 2d 566 (Washington Supreme Court, 2014)
Verizon Northwest, Inc. v. Employment Security Department
164 Wash. 2d 909 (Washington Supreme Court, 2008)
Darkenwald v. Employment Security Department
350 P.3d 647 (Washington Supreme Court, 2015)
Pederson v. Employment Security Department
352 P.3d 195 (Court of Appeals of Washington, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Jessica Tuffley v. Employment Security Department, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jessica-tuffley-v-employment-security-department-washctapp-2024.