Christopher Young v. King County
73521-7
| Wash. Ct. App. | Aug 22, 2016Background
- Christopher Young, an African American senior real property agent (RPA III) at King County Facilities Management Division, had a long, conflictual supervisory relationship with Doug Williams (2007–2012), including a 2010 physical altercation for which both received reprimands.
- Williams repeatedly sought investigations or discipline against Young for attendance and workplace conduct; coworkers also complained about Young's behavior. County investigations sometimes occurred but rarely produced severe discipline.
- Young first asserted racial discrimination in June 2012; HR attempted to investigate but Young provided little further information or cooperation. Williams stopped supervising Young before some later events.
- Young sued King County (Sept. 2013) alleging racial discrimination (disparate treatment and hostile work environment), retaliation, assault, and negligent and intentional infliction of emotional distress; he later sought to amend to add hostile work environment allegations and new factual assertions.
- The trial court denied Young’s motion to amend, granted summary judgment to the County on discrimination, retaliation, assault, and intentional infliction claims, and dismissed negligent infliction of emotional distress for lack of jurisdiction. Young appealed.
Issues
| Issue | Young's Argument | County's Argument | Held |
|---|---|---|---|
| Motion to amend complaint | Amendment was timely and necessary to present a hostile work environment claim and additional facts (Halley conduct, ratification, motive) | Amendment was futile, prejudicial, and would cause undue delay (new allegations post-discovery; contradict record) | Denial affirmed — amendment would be futile and cause undue delay/prejudice |
| Disparate treatment (racial) | Williams and County treated Young less favorably than similarly situated white RPAs (Burke, Perlman); County's reasons were pretextual | County had legitimate nondiscriminatory reasons (attendance violations, misconduct complaints); Young offered no specific comparator evidence | Affirmed — Young failed to present specific, material facts showing similarly situated comparators or pretext |
| Hostile work environment (race or retaliation) | Recurrent aggressive conduct and inadequate employer response created hostile work environment; asks to recognize hostile-environment-by-retaliation theory | Employer investigated/attempted to address complaints; no evidence race or protected activity motivated harassment | Affirmed — facts could show harassment and inadequate corrective action but no evidence of racial or retaliatory motive; new theory rejected |
| Retaliation | Complaints to management were protected activity and County retaliated via investigations, reprimands, and physical incidents | Most adverse actions predated any protected complaint; no decisionmaker knew of complaints when actions occurred; conduct after complaint was not an adverse action | Affirmed — Young failed to show protected activity causally caused adverse employment actions |
| Negligent infliction of emotional distress (NIED) | County’s failure to prevent repeated hostile incidents and managerial ratification caused emotional distress | Employer owed no duty to prevent routine workplace disputes or the inadvertent infliction of emotional distress absent statutory/public-policy mandate | Affirmed — County owed no duty to prevent these workplace conflicts; NIED dismissed |
Key Cases Cited
- Camicia v. Howard S. Wright Constr. Co., 179 Wn.2d 684, 317 P.3d 987 (2014) (summary judgment reviewed de novo; plaintiff must show specific and material facts)
- Davis v. W. One Auto. Grp., 140 Wn. App. 449, 166 P.3d 807 (2007) (discrimination cases often involve competing inferences at summary judgment)
- Scrivener v. Clark Coll., 181 Wn.2d 439, 334 P.3d 541 (2014) (definition of motivating factor for discrimination/causation)
- Domingo v. Boeing Emps.' Credit Union, 124 Wn. App. 71, 98 P.3d 1222 (2004) (prima facie disparate treatment elements and comparator analysis)
- Snyder v. Med. Serv. Corp. of E. Wash., 145 Wn.2d 233, 35 P.3d 1158 (2001) (duty analysis for NIED claims and limits on recovery for workplace disputes)