WPI 330.24 Employment Discrimination—Harassment—Hostile Work Environment—“Manager” and “Managem...
6A WAPRAC WPI 330.24Washington Practice Series TMWashington Pattern Jury Instructions--Civil
6A Wash. Prac., Wash. Pattern Jury Instr. Civ. WPI 330.24 (7th ed.)
Washington Practice Series TM
Washington Pattern Jury Instructions--Civil
April 2022 Update
Part XVI. Employment
Chapter 330. Employment Discrimination
WPI 330.24 Employment Discrimination—Harassment—Hostile Work Environment—“Manager” and “Management”—Definitions
A “manager” is a person who has the authority and power to affect hours, wages, and working conditions. “Management” means one or more managers.
NOTE ON USE
Use this instruction with WPI 330.23 (Employment Discrimination—Workplace Harassment—Hostile Work Environment—Burden of Proof).
The first sentence of this instruction may also be used along with WPI 330.22 (Employment Discrimination—Sexual Harassment—Quid Pro Quo—Burden of Proof). See the Note on Use to WPI 330.22 (Employment Discrimination—Sexual Harassment—Quid Pro Quo—Burden of Proof).
COMMENT
This instruction is drawn from Robel v. Roundup Corp., 148 Wn.2d 35, 48 n.5, 59 P.3d 611 (2002) (“[m]anagers are those to whom the employer has given authority and power to affect the hours, wages and working conditions of the employer's workers”). See also Francom v. Costco Wholesale Corp., 98 Wn.App. 845, 991 P.2d 1182 (2000); Alonzo v. Qwest Commc'n Co., LLC, 178 Wn.App. 734, 752, 315 P.3d 610 (2013); Hotchkiss v. CSK Auto Inc., 918 F.Supp. 2d 1108, 1119–120 (E.D. Wash. 2013) (citing Washington v. Boeing, 105 Wn.App. 1, 11, 19 P.3d 1041 (2000)).
For additional discussion of the manager and supervisor distinction, if any, see Comment to WPI 330.23 (Employment Discrimination—Workplace Harassment—Hostile Work Environment—Burden of Proof).
[Current as of October 2020.]
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