Introduction

In the case of McCormick v. Lake Washington School District, Laurie McCormick appealed a summary judgment order that dismissed her claims against the Lake Washington School District (District) regarding her termination. This case highlights important legal principles surrounding employment contracts, promissory estoppel, and due process rights within the context of Washington State law.

Case Background

Laurie McCormick, a certified teacher in Washington, was employed by the Lake Washington School District from September 8, 1994, to October 6, 1994. She applied for a half-time special education teaching position, which she believed she was verbally offered by Becky Anderson, a District coordinator. McCormick ceased her job search based on this offer and began teaching, only to find out later that the District did not approve her employment due to a negative reference check.

Key Issues and Court Findings

1. Employment Status and Contract Requirements:
   • McCormick claimed she was hired as a permanent teacher and argued that Anderson had apparent authority to make such an offer. However, Washington law (RCW 28A.405.210) requires that teacher employment must be approved by the Board of Directors and formalized through a written contract. The court found that McCormick, an experienced teacher, should have known these requirements and thus could not rely on the verbal offer.
2. Summary Judgment and Contradictory Affidavit:
   • McCormick’s affidavit, filed to oppose the summary judgment, contradicted her earlier deposition testimony. The court ruled that self-serving affidavits that contradict prior depositions cannot create an issue of material fact.
3. Due Process Rights:
   • McCormick argued that her due process rights were violated. The court held that due process protections apply to individuals with more than a unilateral expectation of employment. Since McCormick was not a contractually certified permanent employee but rather an at-will substitute, she was not entitled to due process protections under RCW 28A.405.210.
4. Negligence and Misrepresentation Claims:
   • McCormick asserted that the District was negligent in informing her about her employment status and negligently misrepresented her employment. The court found no statutory basis for these claims and affirmed the District’s adherence to statutory procedures.
5. Promissory Estoppel:
   • McCormick argued that Anderson’s promise created a permanent employment relationship through promissory estoppel. The court rejected this argument, stating that Anderson lacked the authority to make such promises and that McCormick could not justifiably rely on a promise that bypassed statutory procedures.

Conclusion

The court affirmed the summary judgment in favor of the Lake Washington School District, emphasizing the necessity for written contracts and Board approval for employment in public schools. This case serves as a crucial reference for understanding employment laws, due process rights, and the limitations of verbal promises within the educational context in Washington State.

You can read the text of McCormick v. Lake Washington School District: A Case Analysis here: https://casetext.com/case/mccormick-v-lake-washington-school-dist?sort=relevance&resultsNav=false&q=

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