In Duncan v. Alaska USA Federal Credit Union, Inc., Division I of the Washington Court of Appeals reversed the lower court’s granting of summary judgment and ruled that genuine issues of material fact existed regarding Duncan’s breach of contract and wage claim statute claims. Specifically, the Court held that Alaska’s employee handbook contained language that arguably limited Alaska’s ability to review and amend Duncan’s compensation plan to once a year even though Alaska had been doing so every six months. Because of this, the Court also held that summary judgment on plaintiff’s exemplary damages claim was premature in part. The Court did state, however, that “it is beyond dispute that Washington law provides that “a terminable-at-will contract may be unilaterally modified” thereby affirming the lower trial court’s ruling on that issue.
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