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Morris v. Hall2/5/2001
Appellant Harold Morris was hired by Whatcom Community College (WCC) to teach philosophical logic on a quarter-by-quarter basis beginning in the spring of 1995. Each contract described the position as part-time and non-tenured. The contracts were subject to a collective bargaining agreement between the college and the teaching faculty. Toward the end of the 1996 winter quarter, Morris was informed that the college would not be renewing his contract. Shortly thereafter, four female students filed complaints with the Dean of Instruction, accusing Morris of sexual harassment. The student-run school newspaper then published an article outlining the accusations against Morris and reporting the school's decision not to renew his contract.
Morris initiated an action in Whatcom County Superior Court against the four students who had filed complaints against him, the college president, and three senior administrators. Morris accused all of the defendants of tortious interference with a contract and the tort of outrage. He also accused the students of defamation and the school officials of violating his due process and free speech rights. The trial court dismissed Morris's claim on the defendants' summary judgment motion.
Because Morris's claims raise no genuine issues of material fact, we affirm the trial court's grant of summary judgment.
FACTS
Harold Morris was hired by Whatcom Community College in the spring of 1995 to teach Philosophy 112 (Logic). The position was part-time and non-tenured but was covered by the collective bargaining agreement between the school's board of trustees and the teachers' union. Midway through the 1995 spring quarter -- Morris's first quarter at WCC -- a female student complained to the college about Morris's behavior, accusing him of using inappropriate sexual language in class, but stopped short of filing a formal grievance. Defendant Bill Christopher -- WCC's Dean of Instruction -- told Morris about the student's concerns and advised that he be cautious about the use of potentially offensive language in class but took no further action against him.
In July 1995, Dean Christopher met with Morris to discuss the renewal of his contract for the 1995 fall quarter. Dean Christopher communicated his intention to offer Morris a contract renewal, but expressed his desire to avoid any further classroom controversy. Morris taught the fall quarter without conflict, and his contract was renewed for the 1996 winter quarter. Toward the end of February 1996, Dean Christopher notified Morris that he had again received complaints about Morris's conduct in the classroom. He suggested that Morris 'change the perception that' he was 'looking for someone to date.' On March 1, Dean Christopher sent a letter to the students in Morris's class giving them the option of completing the course requirements with another instructor. Then on March 4, Dean Christopher informed Morris that the college would not be offering him another contract when his winter quarter contract expired on March 22.
On March 12, 1996, four female students filed formal complaints with the college, accusing Morris of sexual harassment. The next day, journalists from the student-run school newspaper approached Morris and communicated their intent to publish an article outlining the charges against him. The one-page article published on March 13 included excerpts from the students' complaints, Morris's response to the allegations, and a statement from Dean Christopher lauding Morris's teaching ability. The article did not identify the complaining students, nor did it provide specific details about the nature of Morris's alleged misbehavior.
In Jul
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