Chea v. Men's Wearhouse, Inc
In Chea v. Men's Wearhouse, Inc., 85 Wn. App. 405, 932 P.2d 1261 (1997), Division One upheld a negligent infliction verdict where a supervisor inflicted emotional damage on an employee. Chea is however limited by its facts.
The Chea court specifically recognized, and concurred with, precedent that an employer's disciplinary decisions in response to a workplace personality dispute will not give rise to a negligent infliction claim. Chea, 85 Wn. App. at 413.
Notwithstanding, the Chea court permitted the employee to recover because the employer did not argue at trial the incident at issue was a disciplinary act or in response to a personality dispute. Chea, 85 Wn. App. at 413.