In Roe v. TeleTech Customer Care Management, LLC, a job applicant informed her prospective employer, TeleTech, that she used medical marijuana at home with medical authorization to do so under the Washington State Medical Use of Marijuana Act (MUMA). Roe offered to provide a copy of her medical authorization, but TeleTech declined to receive it. Roe tested positive for marijuana, and her employment was terminated under TeleTech's drug policy providing that applicants must pass a drug test prior to employment. Roe filed an action for wrongful termination, claiming that Washington State's MUMA implied a cause of action against employers who fail to hire a person based on their use of medical marijuana in accordance with MUMA. The Washington Court of Appeal disagreed, and held that MUMA did not impose any duty on private employers to accommodate the use of medical marijuana.