Wash. Court of Appeals published opinion — D2 45174-3-II Order Publishing Opinion.pdf

Gomez and Maddox collected witness statements and conducted interviews regarding the incident.

During the investigation, Cook -Gomez overheard Boyd make statements that she

perceived as threatening. Boyd had been discussing assault rifles with co- workers and the best

way to burn a woman' s body. He also demonstrated how to use a chefs knife in an allegedly

Boyd said, "[ T] hey may fire
threatening manner. Another staff member told Cook -Gomez that

me[,] but they will sure as hell remember me." Ex. 94.

WSH assigned Maddox to investigate Boyd' s alleged threats On January 21, 2010, as a

result of the ongoing investigation, WSH reassigned Boyd to another ward. He was not allowed

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patient interaction during his reassignment. WSH also reported Boyd' s conduct to both the

Department of Health and the police.

During an e -mail exchange on January 22, 2010, Maddox told Cook -Gomez " I don' t trust .

Boyd] about anything as he is known to lie." 3 RP at 349. On January 26, 2010, Boyd told

Maddox' s supervisor that Maddox' s presence at his disciplinary meeting made him uncomfortable.

The supervisor e- mailed a Human Resources representative, who stated that Maddox could still

attend the meeting and WSH would explain her presence as a training exercise.

At the disciplinary meeting, the witness who overheard Boyd say, "[ T] hey may fire me,

but they will sure as hell remember me," told Maddox that Boyd' s comment related to apple cider

and she did not perceive it as threatening. Ex. 23. Maddox discussed the witness' s " apple cider"

explanation with Human Resources but did not include it in the report she provided to WSH' s