The Washington Court of Appeals recently ruled in the case of Yavor Angelov v. Google LLC, affirming a lower court's decision that dismissed Angelov's claims against his former employer, Google. The court found that a severance agreement Angelov signed was valid and enforceable, effectively barring his claims related to his employment and subsequent resignation. This ruling is significant as it clarifies the enforceability of severance agreements in employment disputes.

Yavor Angelov worked as a software engineering manager at Google from January 2021 until his resignation in June 2025. In early 2024, he transferred to a new team under the supervision of Saad Syed, where he experienced an increase in workload and stress. By February 2025, Angelov's health deteriorated, leading to a recommendation for medical leave, which Google approved under the Washington Paid Family and Medical Leave Act (WPFMLA).

Upon returning to work, Angelov faced a formal performance warning from Syed. During this time, he was presented with a severance package that included a release of claims against Google. Angelov resigned under the condition that he would receive this severance, which he signed shortly after. However, he later filed a lawsuit against Google and Syed, claiming that the severance agreement was invalid and alleging violations of the WPFMLA, among other claims.

The trial court dismissed all of Angelov's claims, ruling that the severance agreement was enforceable and precluded his legal actions. Angelov appealed this decision, arguing that the agreement violated the WPFMLA's anti-waiver provision and that he had signed it under duress.

In its ruling, the Court of Appeals reviewed the trial court's dismissal of Angelov's claims. The court noted that the severance agreement included a broad release of claims and that Angelov had signed it voluntarily. The court stated, "The SAR did not waive, release, or commute Angelov’s WPFMLA rights during his employment. After termination, Angelov was no longer entitled to WPFMLA rights through Google." This means that while he had rights under the WPFMLA during his employment, those rights did not extend to claims he could make after his resignation.

The court also addressed Angelov's claims of duress and unconscionability regarding the severance agreement. It found that his assertion of duress did not meet the legal standard, as he had the option to resign with severance or continue working under the performance warning. The court concluded that the circumstances did not demonstrate that Angelov was deprived of his free will.

Regarding unconscionability, the court examined both procedural and substantive aspects. It determined that the severance agreement provided Angelov with sufficient time to consider the terms and the opportunity to consult with an attorney. The court noted that the agreement allowed him 21 days to review it and seven days to revoke it after signing. The court remarked, "The 72-hour deadline did not apply to the SAR, but to the decision to resign with severance or remain at Google." This indicates that Angelov had adequate opportunity to understand and negotiate the terms of the severance agreement.

The court further found that the terms of the severance agreement, which included 18 weeks of salary, were not unconscionable. Angelov's claims that the severance package was inadequate compared to his unvested equity were dismissed, as the court stated that the offered amount did not "shock the conscience." The ruling sets a precedent for the enforceability of severance agreements, particularly in cases involving claims under the WPFMLA. It underscores the importance of understanding the implications of signing such agreements and the conditions under which they can be challenged.

Moving forward, this ruling may influence how severance agreements are drafted and negotiated in the tech industry and beyond. Employees may need to be more vigilant in understanding the terms of these agreements, especially regarding their rights under state laws like the WPFMLA. The case also highlights the need for employers to ensure that their severance agreements are clear and legally sound to avoid potential disputes.

As for the possibility of an appeal, the court's ruling is final unless Angelov seeks further review from the Washington Supreme Court. There are currently no related cases pending that could affect this ruling.