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.