Reynold Quedado, Appellant, v. The Boeing Company, Respondent., 168 Wn. App. 363

Summary

The employee argued that his demotion either violated an implied contract that arose from the employer's Code of Conduct and two more detailed documents, or violated specific promises contained in those documents. The appellate court found that the code made no "offer" of new employment terms or entitlements. The employer's code was likely intended to foster a general atmosphere of fair treatment for its employees. This was not enough to modify the at-will relationship. Read as a whole, the document left the company with ample discretion to impose varying discipline, depending upon how its decision makers viewed the circumstances of each individual case. The documents were guidelines for the benefit of personnel who were in charge of corrective action. They were too general to create a promise to employees that opinions, hearsay, and personal feelings would never play a part in the company's disciplinary process. The documents did not create an implied contract.