Baldwin v. Sisters of Providence in Washington, Inc – Case Brief Summary (Washington)

In Baldwin v. Sisters of Providence in Washington, Inc., 112 Wn.2d 127, 769 P.2d 298 (1989), the Court quoted approvingly from an Oregon Supreme Court opinion addressing a dispute over an employee handbook provision:

"There is a just cause provision, but no express provision transferring authority to make factual determinations from the employer to another arbiter.

Neither is there reason to infer that such a meaning was intended by the terms of the Employee Handbook. . . . The handbook is a unilateral statement by the employer of self-imposed limitations upon its prerogatives. . . . The meaning intended by the drafter, the employer, is controlling and there is no reason to infer that the employer intended to surrender its power to determine whether facts constituting cause for termination exist. . . . In the absence of any evidence of express or implied agreement whereby the employer contracted away its fact-finding prerogative to some other arbiter, we shall not infer it." 112 Wn.2d at 137-38.