Leah Jackson, V. Washington State Employment Security
59636-9
Wash. Ct. App.Jul 8, 2025Background
- Leah Jackson worked as a bartender at Brewmaster’s Bakery.
- The bakery planned a drag queen story hour that led to threatening phone calls and eventually a shooting incident at the business.
- After learning about the shooting, Jackson communicated with the owner mainly to request information about the incident rather than directly reporting a safety concern.
- The owner responded, stating immediate steps had been taken: meeting with police, creating a safety plan, and installing surveillance equipment.
- Jackson resigned, citing lack of communication about safety.
- Jackson's claim for unemployment benefits was initially granted by an ALJ, then reversed by the Employment Security Department Commissioner who found she did not satisfy statutory notice requirements.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Jackson had good cause to quit under RCW 50.20.050 | She quit due to worksite safety deterioration and lack of info | Jackson did not notify employer of safety issue | No good cause: requirements to notify employer not satisfied |
| Whether employer needed to inform employees of corrective steps | Employer must communicate safety measures to employees | Statute only requires employer action, not notice | No requirement to notify employees under law |
| Whether immediate steps were taken by employer | Steps were not communicated, so ineffective | Immediate security steps were actually taken | Immediate steps were taken; no violation by employer |
| Factual sufficiency of notice and corrective measures | Her texts constituted sufficient notice | Texts did not express actual safety concern | Substantial evidence supports the Commissioner's findings |
Key Cases Cited
- Campbell v. Emp't Sec. Dep't, 180 Wn.2d 566 (2014) (summarizes standard of review for agency decisions and liberal interpretation of unemployment statutes)
- Michaelson v. Emp't Sec. Dep't, 187 Wn. App. 293 (2015) (standard for substantial evidence in administrative appeals)
- Pederson v. Emp't Sec. Dep't, 188 Wn. App. 667 (2015) (burden of demonstrating invalidity of Commissioner's findings)
- Gibson v. Emp't Sec. Dep't, 185 Wn. App. 42 (2014) (interpretation of unemployment law and weight to agency expertise)
- Whitehall v. Emp't Sec. Dep't, 25 Wn. App. 2d 412 (2023) (review of Commissioner's decision, not ALJ, in appeals)