IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR KING COUNTY. No.

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1 MARK R. ZMUDA, v. IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR KING COUNTY Plaintiff, CORPORATION OF THE CATHOLIC ARCHBISHOP OF SEATTLE d.b.a. THE ARCHDIOCESE OF SEATTLE, and EASTSIDE CATHOLIC SCHOOL, Defendants. No. PLAINTIFF S COMPLAINT FOR DAMAGES COMES NOW the Plaintiff, Mark R. Zmuda, by and through his attorneys, Richard H. Friedman and Friedman Rubin, and alleges for his complaint against the Defendants as follows: I. JURISDICTION AND VENUE 1. All acts hereinafter alleged occurred within King County, Washington. This Court has jurisdiction over the matter. Washington. II. PARTIES. Plaintiff Mark R. Zmuda was at all relevant times a resident of King County,. Defendant Corporation of the Catholic Archbishop of Seattle, d.b.a. The Archdiocese of Seattle ( the Archdiocese ), was at all relevant times incorporated under the laws of the State of Washington, and is and was doing business in Seattle, King County, Washington. COMPLAINT FOR DAMAGES Page 1 1 UNIVERSITY STREET, SUITE 1 () 01

2 Defendant Eastside Catholic School ( ECS or the School ) was at all relevant times incorporated under the laws of the State of Washington, and was and is doing business in Sammamish, King County, Washington. III. FACTS RELEVANT TO ALL CLAIMS. In May 1, Eastside Catholic School hired Mark Zmuda to be the School s vice principal. Mr. Zmuda began work as vice principal at ECS on or about July, 1. Mr. Zmuda also became the coach of ECS s swimming team.. Mr. Zmuda is a gay man. At the time ECS hired Mr. Zmuda, he lived with his registered domestic partner in Florida. Mr. Zmuda and his partner moved to Washington to allow Mr. Zmuda to work at ECS as vice principal.. On November, 1, Washington voters passed Referendum, approving of Engrossed Substitute Senate Bill. This Bill granted same sex couples the right to marry in the State of Washington.. Mr. Zmuda neither concealed nor volunteered the fact that he was gay while on the job at ECS.. In January, 1, School President Sister Mary E. Tracy, SNJM (hereinafter School President ), CFO Kris Galvin, and School Principal Polly Skinner (collectively referred to as School Administrators ), called Mr. Zmuda into a meeting and asked him directly if he was gay. Mr. Zmuda told them that he was gay, and that he was in a committed relationship with his domestic partner.. The School President told Mr. Zmuda that he was not to bring his partner to any ECS functions. Mr. Zmuda had not ever brought his partner to any ECS functions before the meeting. Mr. Zmuda did not bring his partner to any ECS functions after the meeting either.. ECS knew that Mr. Zmuda was gay from the time of this meeting forward. 1. Pursuant to his legal rights as a resident of the State of Washington, Mr. Zmuda married his domestic partner on July, Mr. Zmuda neither concealed nor volunteered the fact that he was married while on the job at ECS. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

3 Mr. Zmuda performed his duties as vice principal of ECS to the satisfaction and praise of the School, earning a salary increase on September, In fact, the School President wrote to Mr. Zmuda at the time of his salary increase stating he was a wonderful leader and member of our [ECS s] team. She also thanked Mr. Zmuda for his work ethic, commitment to the School s mission, and sense of team.. As vice principal for ECS, Mr. Zmuda s job duties were purely administrative and unrelated to any religious practice or activity. Mr. Zmuda s job duties at ECS were no different than the job duties of a vice principal at a public school or non-religious private school.. Sometime after the School President s September, 1 letter to Mr. Zmuda, she and others at the School suspected that Mr. Zmuda was legally married to his husband.. On November, 1, the School Administrators met with Mr. Zmuda to discuss the fact of his marriage.. At this meeting, Mr. Zmuda acknowledged his marriage. The School Administrators told Mr. Zmuda at this meeting that his marriage was none of their [ECS s] business, and that Mr. Zmuda had full support from the ECS administration.. On November, 1, the School President again met with Mr. Zmuda, this time asking him to confirm that he was legally married. Mr. Zmuda again stated that he was legally married and was in possession of an official marriage certificate.. The School President then informed Mr. Zmuda that his employment at ECS would be terminated unless he filed for a divorce.. The School President also told Mr. Zmuda that if he were to divorce his husband, ECS would pay the costs of holding a commitment ceremony in place of a wedding.. Mr. Zmuda refused to divorce his husband.. On December, 1, the School President informed Mr. Zmuda that she had met with Archbishop J. Peter Sartain (hereinafter the Archbishop ) of the Archdiocese of Seattle and others to discuss Mr. Zmuda s continued employment at ECS in light of his marriage.. The School President informed Mr. Zmuda that he would be terminated because of his status as a married gay man. She said that the decision came from the Archbishop, and not the School. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

4 On December, 1, Mr. Zmuda met with the School President, ECS Board of Trustees Chairman Gene Colin, and Mike Patterson, the attorney for the Archdiocese.. Mr. Patterson told Mr. Zmuda that his marriage to a man was against Catholic teachings and principles. 1. performance.. Mr. Patterson told Mr. Zmuda that his employment would terminate on December,. Mr. Patterson said the reason for Mr. Zmuda s termination was not that he is gay. 0. Mr. Patterson said the reason for Mr. Zmuda s termination was not poor job 1. Mr. Patterson told Mr. Zmuda that the only reason for his termination was that Mr. Zmuda had married his husband, and was in possession of a state-issued marriage certificate.. Prior to Mr. Zmuda s termination, ECS s website represented that ECS does not discriminate based on marital status or sexual orientation: Eastside Catholic School does not discriminate on the basis of an employee s or applicant s race, religion, creed, color, sex, age, national origin, disability, marital status, sexual orientation or any other status or condition protected by local, state or federal law. Discrimination or harassment on the basis of any status or condition protected by local, state or federal law is strictly prohibited and will not be tolerated at Eastside Catholic School.. ECS has since removed this statement from its website.. ECS gave Mr. Zmuda an Employee Handbook when he was first hired. ECS then provided Mr. Zmuda with an updated Employee Handbook on June, 1, one month before he married his husband.. ECS s Employee Handbook states that it does not discriminate based on any status protected by law. On page, the handbook states: Eastside Catholic School does not discriminate with regard to an employee or applicant on the basis of any status or condition which is protected by an applicable law. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

5 In an open communication to the ECS community on December, 1, the School President stated that Mr. Zmuda s employment had been terminated for violat[ing] his employment contract: Dear EC Community, Vice Principal Mark Zmuda's employment with Eastside Catholic has been terminated. His last day will be tomorrow, Friday, December. Mark's same-sex marriage over the summer violated his employment contract with the school. As a Catholic school, Eastside Catholic abides by the official teachings of the Catholic Church, and as such, the decision to discontinue his employment was determined by the Catholic Church. We are grateful for Mark's exemplary service to Eastside Catholic and we wish him the very best. Please contact Sr. Mary Tracy at with any questions. (Emphasis added.). Also on December, 1, the School President held a faculty meeting to inform ECS employees of Mr. Zmuda s termination.. The School President confirmed at this faculty meeting that Mr. Zmuda was being terminated; he did not voluntarily resign.. The School President confirmed at this meeting that the decision to terminate Mr. Zmuda was made by the Archdiocese, and that her hands were tied. 0. On Friday, December, 1, ECS terminated Mr. Zmuda s employment. COUNT I TORTIOUS INTERFERENCE WITH BUSINESS EXPECTANCY 1. Mr. Zmuda was employed as vice principal and head swimming coach at ECS.. Mr. Zmuda performed his job duties to the satisfaction of his superiors, his peers, ECS students, and the ECS Board of Trustees.. The School represented on its website and employee handbook that it would not discriminate against Mr. Zmuda based on a legally protected status, such as marriage or sexual orientation. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

6 Based on the above, Mr. Zmuda had a reasonable expectation that this employment relationship with ECS would continue regardless of whether he married his husband.. Mr. Zmuda did in fact rely on the School s statements and actions, and married his husband.. The Archdiocese is a Catholic institution that is separately incorporated from ECS. The School is not part of the Archdiocese.. Neither the Archbishop nor his delegates sponsor, direct, administer, or manage ECS.. ECS is not accredited by the Archdiocese.. The Archdiocese knew that Mark Zmuda was the vice principal of ECS. 0. When the Archdiocese discovered that Mark Zmuda was married, it took intentional steps to cause Mr. Zmuda s termination at ECS. 1. ECS acquiesced to the Archdiocese s improper efforts to obtain Mr. Zmuda s termination.. The Archdiocese s conduct constitutes intentional interference with Mr. Zmuda s business expectancy or economic relations with ECS.. The Archdiocese s interference was intentionally undertaken for the improper purposes including, but not limited to, making an example out of Mr. Zmuda, harming Mr. Zmuda, or asserting the Archdiocese s power over an independent legal entity.. The Archdiocese s interference was undertaken by improper means.. As a direct result of the Archdiocese s conduct, Mr. Zmuda lost his job and has suffered economic and emotional harm and damages, in an amount to be proven at trial. COUNT II VIOLATION OF WASHINGTON S LAW AGAINST DISCRIMINATION ( WLAD ). As vice principal for ECS, Mr. Zmuda s job duties were purely administrative.. Mr. Zmuda s job duties were wholly unrelated to any religious practice or activity.. Mr. Zmuda s job duties at ECS were no different than the job duties of a vice principal at a public school or non-religious private school. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

7 ECS is subject to civil liability under RCW.0, et. seq., given that Mr. Zmuda s job duties were unrelated to any religious practices or activities. 0. Discrimination in employment on the basis of marital status is prohibited in Washington under RCW.0, et. seq. 1. ECS expressly terminated Mr. Zmuda because he married his husband.. By terminating Mr. Zmuda based on his marital status, ECS unlawfully discriminated against Mr. Zmuda, in direct violation of RCW.0 et. seq.. ECS s unlawful discrimination directly and proximately caused economic and emotional harm and damages to Mr. Zmuda, in an amount to be proven at trial.. Mr. Zmuda is entitled to recover all economic and general damages proximately caused by ECS s unlawful discrimination in violation of WLAD, together with actual costs of litigation, including reasonable attorneys fees. COUNT III BREACH OF IMPLIED CONTRACT/ PROMISSORY ESTOPPEL. Mr. Zmuda was an at-will employee at ECS.. When Mr. Zmuda was hired, he received an Employee Handbook from ECS. ECS then gave Mr. Zmuda an updated Employee Handbook on June, 1. The Handbook sets forth school policies and procedures that Mr. Zmuda was expected to follow.. All excerpts from ECS s Employee Handbook contained herein reference the June, 1 version of the Handbook.. ECS s employee handbook states on page that ECS does not discriminate on the basis of any status or condition which is protected by an applicable law.. ECS s employee handbook states on page that the School will accept and embrace those with different faiths, social, ethnic and economic backgrounds. 0. ECS s employee handbook states on page 1 that it is the School s policy to operate ECS in compliance with all applicable laws and regulations in accordance with the highest ethical standards. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

8 In addition to the handbook, ECS s website stated that it would not discriminate on the basis of an employee or applicant s race, religion, creed, color, sex, age, national origin, marital status, sexual orientation, or any other status or condition protected by local, state or federal laws.. ECS s website further stated that such discrimination will not be tolerated at Eastside Catholic School.. These representations on ECS s website were removed by ECS only after it terminated Mr. Zmuda.. These representations by ECS constitute promises of specific treatment in a specific situation: specifically, that the School would not discriminate against an employee based on his or her marital status or sexual orientation.. ECS should have reasonably expected that its employees would rely on these promises of non-discrimination, and exercise their legal rights to marry.. Mr. Zmuda did in fact rely on ECS s promise not to discriminate, and married his husband.. Mr. Zmuda s reliance on ECS s promises of non-discrimination was reasonable and justifiable under the circumstances.. Despite promising not to discriminate based on marital status or sexual orientation, ECS fired Mr. Zmuda because he married his husband.. By firing Mr. Zmuda for marrying his husband, ECS breached its promise not to discriminate against employees based on their marital status or sexual orientation. 0. ECS s breach of this promise directly and proximately caused economic and emotional harm and damages to Mr. Zmuda. 1. Justice requires that ECS provide Mr. Zmuda with a just and fair remedy that adequately accounts for his losses and damages that flow from ECS s breach of this promise. COUNT IV WRONGFUL TERMINATION IN VIOLATION OF PUBLIC POLICY. The law of Washington recognizes marriage as a civil contract founded on a clear public policy, and encourages it in the interest of morality. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

9 Same-sex marriage is legal in Washington. The state recognizes such unions on equal terms as it does marriages between persons of the opposite sex.. It is a clear public policy in Washington to grant equal protection for all families in Washington by creating equality in civil marriage.. Mr. Zmuda acted lawfully and pursuant to his rights as a citizen of Washington when he married his husband.. Mr. Zmuda s marriage was in accordance with, and in furtherance of, Washington s public policy to encourage marriage.. Mr. Zmuda s marriage was in accordance with and in furtherance of Washington s public policy to grant equal protection to all families by creating equality in civil marriage.. ECS s termination of Mr. Zmuda was based solely on Mr. Zmuda s decision to marry.. ECS s action serves to discourage persons similarly situated to Mr. Zmuda from marrying for fear of retaliation by their employers. 0. Discouraging persons similarly situated to Mr. Zmuda from marrying jeopardizes Washington s public policies of encouraging marriage and granting all families equality in civil marriage. 1. ECS s termination of Mr. Zmuda violates clearly stated public policy in Washington. Such termination constitutes a tort of wrongful termination in violation of public policy.. ECS s wrongful termination of Mr. Zmuda in violation of public policy directly and proximately caused economic and emotional harm and damages to Mr. Zmuda in an amount to be proven at trial. COUNT V VIOLATION OF CONSUMER PROTECTION ACT. ECS represented to the public that it did not discriminate based on an employee or applicant s race, religion, creed, color, sex, age, national origin, marital status, sexual orientation, or any other status or condition protected by local, state or federal laws.. ECS firmly stated that such discrimination will not be tolerated at ECS. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

10 ECS similarly stated in its Employee Handbook that it would not discriminate against employees based on a status or condition that is protected by an applicable law.. Prospective and current employees considering employment at ECS, including Mr. Zmuda, were aware of these non-discrimination statements by ECS.. Likewise, parents considering sending their children to ECS, and those children themselves, were aware of and embraced this purportedly non-discriminatory attitude.. These statements had the capacity to deceive a substantial portion of the public into believing that ECS would not so discriminate.. In fact, Mr. Zmuda was deceived by these statements into believing that he would not be discriminated against based on marital status or sexual orientation. 0. Likewise, parents who had chosen to send prospective students to ECS, and those students themselves, were deceived by ECS s statements. 1. ECS s false and deceptive statement of non-discrimination to prospective and current employees, parents, and students on the School s website constitutes a deceptive act or practice occurring in the conduct of ECS s trade or commerce.. As a result of ECS s deceptive act or practice, Mr. Zmuda married his husband with a reasonable expectation that he would continue to be employed by ECS.. Despite ECS s claims of non-discrimination, ECS did in fact fire Mr. Zmuda based on his marital status or sexual orientation.. ECS s deceptive act affects the public interest because it had the capacity to deceive and injure other persons.. ECS s deceptive act proximately caused injury and damage to Mr. Zmuda s business and/or property.. ECS s deceptive act constitutes a violation of Washington s Consumer Protection Act ( CPA ), RCW., et. seq. As such, Mr. Zmuda is entitled to relief for all damages proximately caused by ECS s deceptive act, as well as other and further damages recoverable under the CPA, including an award of attorneys fees and treble damages up to $,000. COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

11 IV. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for the following: 1. Judgment against the Archdiocese in an amount to be proven at the time of trial, including compensation for the pecuniary loss and benefits of Mr. Zmuda s prospective employment relation with ECS, consequential losses for which the interference is a legal cause, and emotional distress or actual harm to Mr. Zmuda s reputation.. Judgment against ECS in an amount to be proven at the time of trial, including all actual damages, whether in tort or in contract, that were caused by ECS s wrongful termination, together with the costs of the action, including reasonable attorneys' fees and litigation costs, pursuant to Washington's Law Against Discrimination, RCW.0.00(), as well as reasonable attorneys fees, litigation costs, and treble damages up to $,000 pursuant to Washington s Consumer Protection Act, RCW The Court's permission to amend this complaint as necessary if new and material facts are learned during discovery.. For such other and further relief as the court may deem just and equitable, including but not limited to prejudgment interest. DATED this th day of March, 1. By: Richard H. Friedman, WSBA #0 Attorneys for Plaintiff COMPLAINT FOR DAMAGES Page 1 UNIVERSITY STREET, SUITE 1 () 01

1 2 3 4 5 [ATTORNEY NAME] (ATTORNEY STATE BAR NUMBER) [ATTORNEY EMAIL ADDRESS] [LAW FIRM NAME] [LAW FIRM STREET ADDRESS] [LAW FIRM CITY/STATE/ZIP CODE] [LAW FIRM TELEPHONE NUMBER] [LAW FIRM FAX NUMBER]

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