Appeals: Findings of Fact in Employment-Discrimination Cases
Under Washington State laws, how do appellate courts review findings of fact when deciding employment-discrimination cases? Here's my point of view (NOTE: please read our DISCLAIMER before proceeding).
APPELLATE COURTS REVIEW FINDINGS OF FACT FOR SUBSTANTIAL EVIDENCE
Generally, Washington State appellate courts "review findings of fact for substantial evidence." Blackburn v. Department of Social and Health Services, 186 Wn.2d 250, 256 (Wash. 2016) (citing Hegwine v. Longview Fibre Co., 162 Wn.2d 340, 352, 172 P.3d 688 (2007)). This applies to, inter alia, employment discrimination claims.
APPELLANT'S BURDEN: PROVE FINDINGS ARE NOT SUPPORTED BY SUBSTANTIAL EVIDENCE
For purposes of employment discrimination cases, the appellant, "[a]s the party challenging the trial court's factual findings, … [has] the burden to prove … [said findings] are not supported by substantial evidence." Id. (citing Fisher Props., Inc. v. Arden-Mayfair, Inc., 115 Wn.2d 364, 369, 798 P.2d 799 (1990)).
DEFINITION OF SUBSTANTIAL EVIDENCE
The Washington appellate courts have determined the term "'[s]ubstantial evidence' means evidence that is sufficient to persuade a rational, fair-minded person of the truth of the finding." Id. (citing Hegwine, 162 Wn.2d at 353) (internal quotation marks and citations omitted). "So long as this substantial evidence standard is met, 'a reviewing court will not substitute its judgment for that of the trial court even though it might have resolved a factual dispute differently.'" Id. (citing Sunnyside Valley Irrig. Dist. v. Dickie, 149 Wn.2d 873, 879-80, 73 P.3d 369 (2003)).
STANDARD OF REVIEW: DE NOVO
Appellate courts "review conclusions of law de novo." Id. (citing Robel v. Roundup Corp., 148 Wn.2d 35, 42, 59 P.3d 611 (2002); Hegwine, 162 Wn.2d at 348, 353).
LEARN MORE
If you would like to learn more, then consider contacting an experienced Washington State Employment Discrimination Attorney as soon as possible to discuss your case. Please note: the information contained in this article is not offered as legal advice and will not form an attorney-client relationship with either this author or Williams Law Group; please see our DISCLAIMER.
–gw
