Narrative Opinion Summary
In this appellate case, the court reviewed Bonnie Salina's appeal against the district court's summary judgment in favor of her employer, Providence Hospice of Seattle, concerning claims under several employment statutes, including the Washington Law Against Discrimination (WLAD), the Americans with Disabilities Act (ADA), the Family Medical Leave Act (FMLA), and the Employee Retirement Income Security Act (ERISA). The court affirmed the district court's judgment, finding that the nonprofit religious status of the defendant exempted it from WLAD, and Salina had not relied on the equal opportunity policy to invoke estoppel. Her ADA claim was waived due to timeliness issues and jurisdictional limitations. The court found no factual dispute about her termination preceding her FMLA leave application, and Salina provided no evidence that the leave influenced her termination. Her ERISA claim was waived for lack of opposition, and the district court's procedural decisions, including denying an extension and a motion to amend the complaint, were within its discretion. The decision is not published as a precedent, adhering to Ninth Circuit rules.
Legal Issues Addressed
Discretion of the Court in Procedural Matterssubscribe to see similar legal issues
Application: The district court acted within its discretion in denying the appellant's request for an extension to file her opposition brief and her motion to amend the complaint.
Reasoning: The district court acted within its discretion when it denied Salina's request for an extension to file her opposition brief and her motion to amend the complaint.
Estoppel in Employment Discrimination Claimssubscribe to see similar legal issues
Application: The appellant's reliance on the defendant's equal opportunity policy was insufficient to invoke estoppel.
Reasoning: Salina failed to show reliance on Hospice's equal opportunity policy, which means estoppel does not apply.
Exemption of Nonprofit Religious Organizations under WLADsubscribe to see similar legal issues
Application: The court found that the defendant, a nonprofit religious organization, is exempt from coverage under the Washington Law Against Discrimination.
Reasoning: The court found that Providence Hospice of Seattle, as a nonprofit religious organization, is exempt from WLAD coverage.
FMLA Rights and Employment Terminationsubscribe to see similar legal issues
Application: The court found no factual dispute regarding the termination occurring before the FMLA leave application, and no evidence that the leave influenced the termination decision.
Reasoning: There is no factual dispute regarding Salina's termination before her FMLA leave application. Even if she had been on leave, Salina did not provide evidence showing that the leave influenced her termination decision, as the FMLA does not grant additional rights.
Timeliness and Jurisdiction of ADA Claimssubscribe to see similar legal issues
Application: The appellant's ADA charge was dismissed due to waiver and lack of jurisdiction by the Washington State Human Rights Commission over the nonprofit organization.
Reasoning: Her argument regarding the timeliness of her ADA charge was waived and ultimately fails since the Washington State Human Rights Commission lacks jurisdiction over the nonprofit organization.
Waiver of ERISA Claimssubscribe to see similar legal issues
Application: The appellant waived her ERISA claim by not opposing the argument of lack of evidence for interference with benefits.
Reasoning: Salina waived her ERISA claim by not opposing Hospice's argument regarding a lack of evidence for interference with benefits.