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The Court of Appeals of Washington has upheld previous rulings in favor of an employer whose employee suffered serious mental stress due to the actions of a co-worker. The case is Cook-Crist v. Department of Labor & Industries, No. 81325-1-I (Wash. Ct. App. 06/01/21, unpublished).

Julie Cook-Crist worked as an administrative assistant at a company called Network Communications, Inc. (NCI) from 2007 to 2010. Beginning in 2008, a co-worker, Andrea North, began to routinely scream, use profanity and lash out at Cook-Crist without any provocation. North would frequently engage in aggressive behavior including slamming doors and stomping around the office. Cook-Crist began to dread interactions with North and was in constant fear of the next outburst, likening the relationship to a domestic abuse situation. Cook-Crist attempted to address the situation to North directly but was unsuccessful, so she sought assistance from her supervisor Terry Fritz. Fritz failed to adequately address the concerns.

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