Garibay

MEMORANDUM **

The district court’s grant of summary judgment must be affirmed because there is no genuine issue of material fact that Komatsu and Komatsu Electronics Metals Co. (“KEM”) owed Garibay a duty. Quadrant Corp. v. Am. States Ins. Co., 110 P.3d 733, 737 (Wash.2005). Under Washington state law, a parent corporation is not liable for the acts of a subsidiary unless the parent deliberately manipulated the subsidiary to avoid a legal duty. See Minton v. Ralston Purina Co., 146 Wash.2d 385 , 47 P.3d 556, 562 (2002). “Mere common ownership of stock, the same officers, employees, etc., does not justify disregarding the separate corporate identities unless a fraud is being worked upon a third person.” Rena-Ware Distribs., Inc. v. State, 77 Wash.2d 514 , 463 P.2d 622, 625 (1970). Because Garibay presents no evidence that Komatsu and KEM abused ASIMI’s separate corporate form to avoid a legal duty, the district *165 court’s grant of summary judgment must be upheld.

Garibay also appeals the district court’s issuance of an oral decision. The district court entered a written order granting summary judgment but explained its reasoning orally. Under these circumstances, no more…