May
May v. Honeywell International, Inc.
Opinion
lead Opinion
MEMORANDUM **
Barbara May (“May”) appeals from the district court’s grant of summary judgment in favor of appellees Honeywell International, Inc. (“Honeywell”) and Metropolitan Life Insurance Company (“MetLife”) on claims for breach of contract and violations of the Washington Wage Act, Washington Consumer Protection Act, Washington discrimination law and ERISA.
1. Breach of Contract
May argues that Honeywell breached its contractual obligation to pay her short-term disability (“STD”) benefits in accordance with the company’s STD benefits program. Under Washington law, a contract is formed where there is an objective manifestation of mutual assent to the contract. See Keystone Land & Dev. v. Xerox Corp., 152 Wash.2d 171 , 94 P.3d 945 , 949 (2004). Washington courts have also held that an employer who “creates an atmosphere of ... fair treatment with promises of specific treatment in specific situations and an employee is induced thereby to remain on the job and not actively seek other employment, those promises are enforceable components of the employment relationship.” Thompson v. St. Regis Paper Co., 102 Wash.2d 219 , 685 P.2d 1081, 1088 (1984) (emphasis in original). The STD…