Amos v. Kalama School District, 3:24-cv-05335

Plaintiff Lindsay Amos brought a wrongful termination suit against the Kalama School District and related defendants.
Amos previously worked as a reading specialist but was involuntarily transferred to a first-grade instructor role.
Amos alleged her transfer and subsequent resignation amounted to constructive discharge in violation of public policy.
The Court previously denied summary judgment on Amos’s First Amendment retaliation claim but granted summary judgment on her state whistleblower claim.
The sole remaining issue addressed here was Amos’s wrongful, constructive discharge claim, for which she was given a chance to present further evidence.
The Court found no evidence that Amos's working conditions were objectively intolerable as required for constructive discharge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Wrongful constructive discharge (public policy)	Transfer made working conditions intolerable, forcing resignation	No competent evidence of intolerable conditions; transfer alone not sufficient	No genuine dispute of material fact; granted summary judgment for defendants

Snyder v. Med. Serv. Corp. of E. Washington, 35 P.3d 1158 (Wash. 2001) (recognizing claim for constructive wrongful discharge in violation of public policy)
Peiffer v. Pro-Cut Concrete Cutting & Breaking Inc., 431 P.3d 1018 (Wash. Ct. App. 2018) (setting out elements for wrongful discharge/constructive discharge)
Barnett v. Sequim Valley Ranch, LLC, 302 P.3d 500 (Wash. Ct. App. 2013) (constructive discharge standard is objective, based on intolerable working conditions)
Haubry v. Snow, 31 P.3d 1186 (Wash. Ct. App. 2001) (question of intolerable conditions generally for trier of fact unless no evidence)
Travis v. Tacoma Pub. Sch. Dist., 85 P.3d 959 (Wash. 2004) (employee's subjective belief insufficient for constructive discharge)