Court of Appeals Rejects University of Washington Lecturer's Breach of Contract Claim
Lecturers in the University of Washington’s Educational Outreach Program (“Outreach Lecturers”) suffered a loss on February 16, 2010, when the Washington Court of Appeals affirmed the trial court’s judgment in favor of the University on their breach of contract claims. The Outreach Lecturers alleged that the University breached an alleged contract with the lecturers when it failed to abide by the University Handbook’s Faculty Salary Policy (“FSP”). In Washington, under certain conditions, where an employee handbook promises specific treatment in specific situations, thereby inducing an employee to remain in her employment based on that promise, the employee handbook may give rise to a contractual obligation. According to the Outreach Lecturers, the FSP within the University’s Handbook specifically guaranteed pay raises for meritorious faculty, but the University did not issue such pay raises, breaching the alleged contract set forth in the FSP. The trial court granted summary judgment in favor of the University, finding that as a matter of law the Outreach Lecturers’ claims failed. On appeal, the Washington Court of Appeals affirmed, finding that the Outreach Lecturers fell outside the definition of “faculty” as set forth in the FSP, rendering the FSP inapplicable. Separate contracts and a specific “Extension Lecturer’s” manual, not the FSP, governed the Outreach Lecturers’ employment relationship with the University.
