Ryan Anderson v. Seattle Athletic Club - Appeal Dismissed for Failure to Cite Authority
Summary
The Court of Appeals of Washington, Division One, dismissed pro se appellant Ryan Anderson's appeal in their lawsuit against Seattle Athletic Club. The dismissal was based on RAP 10.3(a)(6), which requires appellants to provide argument with citations to the record and legal authority. The underlying trial court had dismissed Anderson's complaint with prejudice for failure to comply with a court order to file a more definite statement regarding their claims for retaliation, discrimination, and labor violations. The appellate opinion was designated non-precedential.
What changed
The Court of Appeals of Washington dismissed Anderson's appeal for failure to comply with RAP 10.3(a)(6), which mandates that appellants include argument with citations to the record and relevant legal authority in their briefs. This procedural dismissal affirms the trial court's earlier dismissal of Anderson's lawsuit against Seattle Athletic Club, which had been dismissed with prejudice for failure to file an amended complaint as ordered.
Pro se litigants in Washington state courts should ensure their appellate briefs comply with procedural requirements, including proper citations to the record and legal authority. The non-precedential status of this opinion limits its value as precedent but underscores the importance of procedural compliance in appellate practice.
What to do next
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Apr 14, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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April 13, 2026 Get Citation Alerts Download PDF Add Note
Ryan Anderson, V. Seattle Athletic Club
Court of Appeals of Washington
- Citations: None known
- Docket Number: 88177-9
Precedential Status: Non-Precedential
Lead Opinion
IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
DIVISION ONE
RYAN ANDERSON, No. 88177-9-I
Appellant,
v. UNPUBLISHED OPINION
SEATTLE ATHLETIC CLUB,
Respondent.
BOWMAN, A.C.J. — Ryan Anderson sued Seattle Athletic Club (SAC) for
retaliation, discrimination, and labor and industry violations. Anderson appeals
the trial court’s order dismissing their1 lawsuit with prejudice under CR 12(b)(6)
and (e). Because Anderson fails to provide argument with citations to the record
and legal authority, we dismiss their appeal under RAP 10.3(a)(6).
FACTS
On March 5, 2024, Anderson began working for SAC as a part-time hourly
employee. On October 14, SAC terminated Anderson. On October 17,
appearing pro se, Anderson sued SAC for retaliation, discrimination, and labor
and industry violations. They alleged that SAC engaged in retaliation by
terminating them because they asked for a pay raise, raised labor and industry
issues, and reported work violations to management. Anderson also alleged
1
Because Anderson uses they/them/their pronouns, we do the same. We mean
no disrespect by doing so.
No. 88177-9-I/2
discrimination based on SAC’s “hostile work environment where they never felt
welcome” and because coworkers gossiped, bullied, and ignored them. Finally,
Anderson’s labor and industry violations claim alleged “no lunch breaks,”
“working off clock,” and having to “supervise[ ] minors with no payment for extra
work.” Anderson requested damages of $135,000, a letter of recommendation
“for their excellent work performance,” amendment of a no-trespass order, and
an order requiring SAC to follow labor and industry requirements.
On January 16, 2025, SAC moved to dismiss the lawsuit under CR
12(b)(6) for failure to state a claim. Alternatively, it moved under CR 12(e) for an
order requiring Anderson to amend their complaint and provide a more definite
statement. On February 21, the trial court held a hearing on the motions. The
court denied SAC’s motion to dismiss but granted its CR 12(e) motion for a more
definite statement, ordering Anderson to file and serve an amended complaint on
SAC by March 21. It instructed Anderson to “allege specific facts, which if
accepted as true, would be a basis for granting the relief requested.” And it
explained that if Anderson failed to comply, it may dismiss their case entirely or
certain claims with prejudice.
By March 21, 2025, Anderson had not filed an amended complaint.2 On
April 4, SAC renewed its motion to dismiss. On May 2, after a hearing, the trial
2
On March 2, 2025, Anderson e-mailed SAC notes that they took “immediately
after [they] were terminated.” On March 5, SAC responded, “I do not believe it meets
the legal requirement for a more definite statement. Your complaint should be amended
to reflect the facts supporting your claims.” SAC later told Anderson to file their
amended complaint with the court clerk. On March 24, Anderson e-mailed SAC again,
stating, “I do not have anything new to add to the case so there is no need to submit an
amendment to my complaint.”
2
No. 88177-9-I/3
court dismissed Anderson’s claims with prejudice under CR 12(b)(6) and (e).
Anderson appeals.
ANALYSIS
Appearing pro se on appeal, Anderson argues the trial court erred by
dismissing their lawsuit because they misunderstood the court’s order requiring
them to file an amended complaint. SAC argues that we cannot consider
Anderson’s appeal because their brief lacks citations to the record and sufficient
legal argument. We agree with SAC.
RAP 10.3(a)(6) directs an appellant to provide a brief with “argument in
support of the issues presented for review, together with citations to legal
authority and references to relevant parts of the record.” And when an appellant
fails to present developed argument for our consideration on appeal, we do not
address their challenge. West v. Thurston County, 168 Wn. App. 162, 187, 275
P.3d 1200 (2012); see also Holland v. City of Tacoma, 90 Wn. App. 533, 538,
954 P.2d 290 (1998) (“Passing treatment of an issue or lack of reasoned
argument is insufficient to merit judicial consideration.”).
Here, Anderson fails to support their arguments with any reference to the
record or citation to authority. And they make no argument about the substantive
issues in their complaint. Instead, they raise separate issues lacking developed
argument and legal authority. While we recognize Anderson is a pro se litigant,
we must hold pro se litigants to the same standards as attorneys. In re Est. of
Little, 9 Wn. App. 2d 262, 274 n.4, 444 P.3d 23 (2019). So, we do not address
their challenges.
3
No. 88177-9-I/4
We dismiss Anderson’s appeal under RAP 10.3(a)(6).
WE CONCUR:
4
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