Lawrence v. Star Protection Agency LLC

CourtDistrict Court, W.D. Washington
DecidedMarch 6, 2023
Docket2:21-cv-00299
StatusUnknown

This text of Lawrence v. Star Protection Agency LLC (Lawrence v. Star Protection Agency LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lawrence v. Star Protection Agency LLC, (W.D. Wash. 2023).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 JAMES A. LAWRENCE, JR., CASE NO. 2:21-cv-00299-LK 11 Plaintiff, ORDER GRANTING 12 v. DEFENDANT’S MOTION FOR SUMMARY JUDGMENT 13 STAR PROTECTION AGENCY LLC, 14 Defendant. 15

16 Plaintiff James A. Lawrence, Jr., a former mobile patrol officer for Star Protection Agency, 17 was terminated after he “medicated” with marijuana before a shift and then drove a company 18 vehicle over a curb. He then sued Star Protection for discrimination, retaliation, failure to 19 accommodate, harassment, breach of contract, and “employment negligence.” Star Protection 20 moves for summary judgment on all claims. Dkt. No. 26. The Court grants its motion. 21 I. BACKGROUND 22 A. Mr. Lawrence Interviews with Star Protection and Completes its Onboarding Process 23 In January 2019, Mr. Lawrence was employed with Toyota of Lake City and looking for a 24 new job. Dkt. No. 37 at 6. That month, Mr. Lawrence interviewed with Star Protection for a mobile 1 patrol officer position. Id. at 7; see Dkt. No. 35 at 3. Star Protection is a private security agency 2 based in Bellevue, Washington that provides clients various professional security services, 3 including mobile vehicle patrol and security consulting. Dkt. No. 35 at 1; Dkt. No. 1-1 at 2. 4 According to Mr. Lawrence’s amended complaint, he disclosed to Star Protection’s

5 recruiter Justin Way during this interview that (1) he was seeking a new job because his current 6 job “did [n]ot best suit [his] disabilities,” and (2) he “used [m]edication to alleviate [his] 7 [i]njuries.” Dkt. No. 37 at 7; see also Dkt. No. 36 at 1–2, 10. Way avers that Mr. Lawrence never 8 disclosed that “he was using medicinal cannabis for a disability,” and notes that if he had, Way 9 would have told him “the company could not hire him due to its zero tolerance policy.” Dkt. No. 10 31 at 2–3. Way also states that he “discussed the physical requirements of the job” with Mr. 11 Lawrence during the initial screening interview. Id. at 2. 12 Mr. Lawrence next interviewed with mobile patrol manager Jim Hatfield and supervisor 13 Caleb Galati. Dkt. No. 37 at 7; Dkt. No. 35 at 3. They discussed “general schedule availability,” 14 which Mr. Lawrence alleges consisted of four 10-hour shifts. Dkt. No. 37 at 7. Notably, Star

15 Protection’s Senior Director of Human Resources states that the company “requires all mobile 16 officers to work overtime,” and that this policy “is discussed with each candidate during the initial 17 interview, and is described in Overtime policy in the Employee Handbook and officer job 18 descriptions.” Dkt. No. 35 at 2. Indeed, the job descriptions for the Motor Patrol Officer and 19 Security Officer positions—which Mr. Lawrence electronically signed on January 28, 2019—list 20 the ability to “stand, walk, and/or drive for up to 90% of an 8-12 hour shift” and the ability to 21 “work up to 12 hours straight” as “physical requirements.” Id. at 59–60, 62, 64–66. Star 22 Protection’s Employee Handbook—which Mr. Lawrence signed on January 30, 2019—states that 23 “[o]ccasionally some overtime may be required of nonexempt employees” and “[w]orking

24 assigned overtime is an important part of each nonexempt employee’s job responsibilities.” Dkt. 1 No. 35 at 17, 55. The Handbook also states that “All Security Officer related positions typically 2 provide services to our clients on a 24 hour/7 day a week basis, so their schedules will vary based 3 on agreed upon hours of assignment.” Id. at 15. On the same day he signed the Security Officer 4 and Motor Patrol Officer job descriptions, Mr. Lawrence identified himself as “[n]ot [d]isabled”

5 on a Voluntary EEO Self-Identification Form. Dkt. No. 37 at 7; Dkt. No. 35 at 88. 6 As part of his hiring and onboarding, Star Protection required Mr. Lawrence to pass 7 multiple screenings, including a background check and drug test, to complete several trainings, 8 and to review and acknowledge receipt of Star Protection’s Employee Handbook and Accident 9 Prevention and Safety Program. Dkt. No. 37 at 7–8; Dkt. No. 35 at 2–3, 55, 57, 68–79. The 10 Employee Handbook includes a strict zero tolerance drug and alcohol policy prohibiting the use 11 of alcohol or drugs “while on the job or in any other manner that may affect the employee’s work 12 performance,” and permits testing at the company’s discretion. Dkt. No. 35 at 28–29. Similarly, 13 the Accident Prevention and Safety Program—which Mr. Lawrence signed on March 13, 2019— 14 states that “[w]orking under the influence of alcohol or illegal drugs or using them at work is

15 strictly prohibited and grounds for immediate termination.” Id. at 74, 79. 16 B. Mr. Lawrence Asks to Not Work Overtime 17 On April 28, 2019, Mr. Lawrence texted Galati shortly before he was scheduled to work 18 an overtime shift, apologizing for the “late notice” and stating, “I was planning on coming in but 19 my neck is saying stay home and lay down so In other words I won’t be able to come in today.” 20 Dkt. No. 35 at 83. He explained that “it wouldn’t be a good idea to work today and put extra strain 21 on my neck as I still feel after effects from a Car Accident where I was Rear Ended a Year ago.” 22 Id. at 81, 83; Dkt. No. 37 at 8; Dkt. No. 29 at 1. Mr. Lawrence also called Hatfield to discuss his 23 neck pain related to the 2018 accident and to express his desire to be excused from working

24 overtime. Dkt. No. 37 at 8–9; Dkt. No. 35 at 84. 1 Mr. Lawrence’s last-minute text did not comport with Star Protection’s policy of giving at 2 least four hours’ notice, and on May 1, 2019, Galati and Hatfield met with Mr. Lawrence to give 3 him a Disciplinary Action Form (“DAF”). Dkt. No. 37 at 9; Dkt. No. 35 at 22, 34–35, 81, 85–86. 4 Mr. Lawrence refused to sign the DAF. Dkt. No. 37 at 9; Dkt. No. 35 at 82, 85–86. During the

5 meeting, the three also discussed Mr. Lawrence’s ability (or lack thereof) to work mandatory 6 overtime. Dkt. No. 37 at 85–86; Dkt. No. 36 at 10. 7 Around this time, Galati offered Mr. Lawrence a static officer position, which would not 8 require Mr. Lawrence to work overtime. Dkt. No. 37 at 9; Dkt. No. 29 at 2; see also Dkt. No. 35 9 at 1–2 (mobile patrol officers “provide random checks for businesses and physical security checks, 10 parking control, removal of unauthorized persons, and emergency responses, while static officers 11 provide on-site security without the use of a vehicle.”). Mr. Lawrence declined this offer because 12 it would pay less. Dkt. No. 37 at 9; Dkt. No. 29 at 2. Mr. Lawrence also alleges he was not 13 interested because he would be “standing all day in a static position.” Dkt. No. 37 at 9; see Dkt. 14 No. 36 at 10. Star Protection asked Mr. Lawrence to provide medical documentation to support his

15 request for an accommodation, but he did not do so. Dkt. No. 29 at 2. Mr. Lawrence claims Hatfield 16 told him he did not care about Mr. Lawrence’s health and that he “d[id] not want medical 17 information[.]” Dkt. No. 37 at 9; Dkt. No. 36 at 10. 18 C. Mr. Lawrence Accumulates More DAFs, Culminating in Termination After He Runs a Star Protection Vehicle Over a Curb 19 On May 16, 2019, Mr. Lawrence failed to show up or call out for his scheduled shift. Dkt. 20 No. 35 at 90–91. Although his supervisor called and left messages to try to figure out where Mr. 21 Lawrence was, Mr. Lawrence did not return any calls until the next day. Id. at 90. He claimed he 22 could not make a phone call until then due to an anxiety attack. Id. The resulting DAF stated that 23 it was Mr. Lawrence’s “final notice,” and that if he failed to follow the call-out procedure again, 24 1 he would be suspended pending investigation and possibly terminated. Id.

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Lawrence v. Star Protection Agency LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawrence-v-star-protection-agency-llc-wawd-2023.