Public Policy Tort Actions In Washington

In Gardner v. Loomis Armored, Inc., 128 Wn.2d 931, 936, 913 P.2d 377 (1996), the Court established a framework for discerning a clear mandate of public policy. What constitutes such a clear mandate is a question of law. The Court generally allowed public policy tort actions in four situations: (1) where employees are fired for refusing to commit an illegal act; (2) where employees are fired for performing a public duty or obligation; (3) where employees are fired for exercising a legal right or privilege; (4) where employees are fired in retaliation for reporting employer misconduct. See Gardner, 128 Wn.2d at 936.