FILED

16 JUN 03 AM 9:00

KING COUNTY
SUPERIOR COURT CLERK
E-FILED
CASE NUMBER: 16-2-13107-7 SEA

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SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

______________________________________________________________________________
PATRICK JONES, individually;
Case No. ___________________

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Plaintiff,

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COMPLAINT FOR MANDATORY

INJUNCTION REGARDING FALSE
STATEMENTS, DEFAMATION, FALSE
LIGHT

v.

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BELLEVUE SCHOOL DISTRICT 405,

A public school district
Defendants.
______________________________________________________________________________

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1.0

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1.1

PARTIES

Plaintiff Patrick Jones is a resident of King County, Washington, and has coached

high school football within the State of Washington for the past 34 consecutive years.
1.2

Defendant Bellevue School District 405 (BSD) is a public school district within

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King County, Washington.

2.0

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2.1

JURISDICTION AND VENUE

The court has jurisdiction over Defendant BSD because it is a public school

district within the state of Washington.

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PAGE 1 - COMPLAINT
JONES LAW OFFICE, P.L.L.C.
11819 NE 34TH STREET
BELLEVUE, WA 98005
(425) 576-8899

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2.2

The venue is proper as the Bellevue School District offices are within King

County, the plaintiff resides in King County.

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3.0

FACTUAL BACKGROUND

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3.1

Plaintiff Jones is the assistant head coach of the Bellevue High School varsity

football program. He coached for the football program at Bellevue High School from 1982-1994
and then from 2002 to present. He has coached football at one other Washington state school

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during the 1995 season and another BSD school from 1996-2001 seasons.
3.2

During the week of May 16, 2016, Plaintiff Jones inquired of the Bellevue High

School (BHS) Athletic Director, Lauren McDaniel stating, with all this going on should I deal
with handing out the gear for spring football and move forward as a coach at Bellevue High

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School? Ms. McDaniel replied to Mr. Jones, you are and you should.
3.3

Plaintiff Jones worked approximately 20 hours the week of May 23, 2016,

handing out gear to and fitting equipment for the Bellevue High School football players for the
2016-17 season.

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3.4

On May 27, 2016, Mr. Jones was informed by Human Resources Director Dr. Jeff

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Thomas that Dr. Thomas had prepared a report stating that Plaintiff Jones received a high school

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coaching stipend or gift in excess of $500 in a season, which was not approved by the school

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board of directors. This statement is false.

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3.5

Upon hearing this false statement, Plaintiff Jones, through counsel, immediately

inquired as to what person or entity Dr. Thomas determined paid Plaintiff Jones. Dr. Thomas

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PAGE 2 - COMPLAINT
JONES LAW OFFICE, P.L.L.C.
11819 NE 34TH STREET
BELLEVUE, WA 98005
(425) 576-8899

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responded1, I cant say that definitively. I can only go by the information that Pat has provided.
When Plaintiff Jones counsel followed up by asking, Can we agree that Pat has not provided

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any information to you that shows he has gotten paid personally by anyone? Dr. Thomas

responded, I can neither agree nor disagree because that is not a question that I asked Pat.

Thus, Dr. Thomas is knowingly fabricating that Plaintiff Jones has received money from anyone

in violation of the rule because he admittedly never asked the question.

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3.6

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excess of $500 for coaching high school football, this became the position of Defendant BSD.

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Despite never asking Plaintiff Jones whether he had received a stipend or gift in

3.7

Defendant BSDs Athletic Director Jeff Lowell and the Bellevue High School

Athletic Director Lauren McDaniel self-reported to the KingCo Hearing Panel that two coaches

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had committed violations by receiving a high school coaching stipend or gift in excess of $500 in

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a season, which was not approved by the school board of directors. This statement was made on

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May 23, 2016 to the KingCo Hearing Panel2 in writing with regard to allegation numbers 7 and 8

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with the words there was a violation of WIAA Rule 23.1.1 and upon information and belief the

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statement was also made verbally.

3.8

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In the May 23, 2016, correspondence to the KingCo Hearing Panel, Defendant

BSD wrote: Although there is a finding of violation of WIAA Rule 23.1.1 by two individuals,
there is no athletic sanction to propose as BHS and BSD believes that internal remedies are

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The quoted language is taken from an audio recording of the May 27, 2016 meeting.
The KingCo Hearing Panel is mandated by the Washington Interscholastic Activities Association (WIAA) of which
BSD is a member. All member schools and their coaches are required to comply with the WIAA rules or face
sanctions. WIAA members are required to self-report violation when they learn of them.

PAGE 3 - COMPLAINT
JONES LAW OFFICE, P.L.L.C.
11819 NE 34TH STREET
BELLEVUE, WA 98005
(425) 576-8899

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sufficient to provide the hearing panel with assurances that no further violations will occur. The
internal remedies referred to by Defendant BSD were identified by subsequent actions that same

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week.
3.9

On May 25, 2016, one other BHS Football Coach, which was not Plaintiff Jones,

was informed that he was placed on administrative leave and recommended for termination. On
May 27, 2016, Dr. Thomas attempted to not renew Plaintiff Jones contract with BSD for the

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2016-17 season. By inference, it is now clear that Plaintiff Jones was one of the two individuals
referred to in the May 23, 2016 correspondence to the KingCo Hearing Panel (paragraph 3.8).
3.10

Dr. Thomas attempt to not renew Plaintiff Jones contract was unsuccessful

because he had not been informed by the BHS Athletic Director, Ms. McDaniel, that she had

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already authorized Plaintiff Jones to begin work and confirmed his position to move forward as a

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coach at Bellevue High School (paragraph 3.2). Dr. Thomas indicated to Plaintiff Jones that this

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was new information that he would have to look into and he would get back to Plaintiff later that

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day. Dr. Thomas subsequently extended his time to the following work day but even several days

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later Dr. Thomas has failed to notify Plaintiff as to his subsequent findings on this issue.
3.11

In the meantime, Plaintiff Jones informed Dr. Thomas and Defendant BSD that he

has been coaching high school football continuously since 1982. He affirmatively stated that he
has not received any high school football coaching stipend or gift exceeding $500 at any time

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during his 34 year coaching career other than his regular school district provided coaching
stipend.

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PAGE 4 - COMPLAINT
JONES LAW OFFICE, P.L.L.C.
11819 NE 34TH STREET
BELLEVUE, WA 98005
(425) 576-8899

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3.12

On May 31, 2016, Plaintiff Jones sent a demand to the BSD to immediately

withdraw the false statement you have made to KingCo and provide me proof of the withdrawal.

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3.13

Defendant BSD has failed to heed the demand and remedy the publication of a

false statement.

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4.0

CAUSES OF ACTION

As a first cause of action against Defendant BSD, Plaintiff Jones alleges as follows:

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(Mandatory Injunction Regarding False Statements/Defamation)

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4.1

Plaintiff Jones restates and incorporated by reference paragraphs 1.1 through 3.13.

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4.2

Defendant BSDs statement in their May 23, 2016 letter and oral report to KingCo

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regarding two coaches and/or two individuals having violated WIAA Rule 23.1.1 is false.

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4.3

Defendant BSDs statement was intended to reference Plaintiff Jones having

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received a high school football coaching stipend or gift exceeding $500 without approval by the

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schools board of directors and this statement is false.

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4.4

Defendant BSD is at fault for making a false statement affecting the coaching

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career and unblemished record of Plaintiff Jones. Defendant BSD was reckless in making the

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statement when Dr. Thomas admitted he had never inquired as to any stipends or gifts to

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Plaintiff.

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4.5

Defendant BSDs statements were intended to be relied upon by the KingCo

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Hearing Panel which has the ability to sanction Jones, BSD, the football program and/or the past
or present football teams.

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PAGE 5 - COMPLAINT
JONES LAW OFFICE, P.L.L.C.
11819 NE 34TH STREET
BELLEVUE, WA 98005
(425) 576-8899

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4.6

Defendant BSDs statement has subjected Plaintiff Jones to public hatred,

contempt, ridicule, impairment of reputation and standing in the community, and has deprived

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him of public confidence and social activity. Plaintiff Jones has been damaged by mental
anguish and suffering.
4.7

Plaintiff Jones seeks a court order permanently enjoining Defendant BSD from

making such false statements and a mandatory injunction requiring Defendant BSD to report to

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the KingCo Hearing Panel, the SeaKing District 2 and the WIAA that the statements made were

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false and therefore are not to be relied upon, and to take all action to unwind the actions and

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harm that will be done during the pendency of this action before court orders are in place.

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As a second cause of action against Defendant BSD, Plaintiff Jones alleges as follows:

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(False Light)

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4.8

Plaintiff Jones restates and incorporated by reference paragraphs 1.1 through 4.7

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4.9

Defendant BSD publicized a matter that placed Plaintiff Jones in a false light.

4.10

Plaintiff Jones, in the position of a reasonable person, is highly offended by

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Defendant BSDs actions in reporting a violation to a quasi-judicial body, without any prior

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notice to Plaintiff Jones, such that Plaintiff Jones may have sanctions leveled against him and

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others he deeply cares about based upon information that was determined by Defendant BSD

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who never even inquired into the facts supporting its conclusion.

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4.11

Defendant BSD through Dr. Thomass incompetent investigative actions,

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recklessly disregarded the falsity of his determination that Jones had received a high school

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football coaching stipend or gift exceeding $500 other than his regular school district provided

PAGE 6 - COMPLAINT
JONES LAW OFFICE, P.L.L.C.
11819 NE 34TH STREET
BELLEVUE, WA 98005
(425) 576-8899

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coaching stipend. Defendant BSD then recklessly published the information to the KingCo
Hearing Panel for sanctions and publication.

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4.12

Plaintiff has been personally damaged by mental anguish and suffering.

5.0

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PRAYER FOR RELIEF

5.1

WHEREFORE, plaintiff prays as follows:

(a)

For an Order by this court declaring the Bellevue School District 405 to

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immediately notify the KingCo Hearing Panel that BSDs May 23, 2016 letter and oral

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presentation with regard to allegations numbers 7 and 8 to the KingCo Hearing Panel is false and

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instruct the KingCo Hearing Panel, SeaKing District 2 and the Washington Interscholastic

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Activities Association that they may not rely upon or take action upon the veracity of the

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Bellevue School Districts May 23, 2016 letter or oral presentation until further order of this
court.
(b)

For an Order requiring BSD to unwind any actions that the KingCo Hearing

Panel, SeaKing District 2 and the Washington Interscholastic Activities Association has taken

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based upon the false information provide.

(c)

For an Order requiring the Bellevue School District 405 to maintain the status quo

of all persons (two coaches) referenced in the Bellevue School Districts May 23, 2016 letter and
oral presentation with regard to allegations numbers 7 and 8 as of May 23, 2016.

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(d)

For an Order enjoining the Bellevue School District 405 from making any

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statements to anyone but particularly the Washington Interscholastic Activities Association,

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KingCo Hearing Panel or SeaKing District 2 that two coaches received a high school coaching

PAGE 7 - COMPLAINT
JONES LAW OFFICE, P.L.L.C.
11819 NE 34TH STREET
BELLEVUE, WA 98005
(425) 576-8899

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stipend or gift in excess of $500 in any season, other than what was approved by the school board
of directors" or the vernacular that there was a violation of WIAA rule 23.1.1 which states:

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Coaching stipends and all gifts to a coach exceeding a total of $500 in a season must be approved
by the schools board of directors.

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(e)

For all available damages for false light and defamation as determined by the trier

(f)

For other relief including attorneys fees and costs if there is a legal basis and the

of fact.

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Court deems just and equitable.

DATED this 2nd day of June, 2016.

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JONES LAW OFFICE, P.L.L.C.

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/s/ Marianne K. Jones

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MARIANNE K. JONES, WSBA #21034

Attorney for Plaintiff Jones

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PAGE 8 - COMPLAINT
JONES LAW OFFICE, P.L.L.C.
11819 NE 34TH STREET
BELLEVUE, WA 98005
(425) 576-8899