wage violation (Washington) · Go Syfert
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wage violation in Washington

11 Washington opinions name it 2 courts 2014–2025 4 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Hill v. Garda CL Nw., Inc.green
wash · 2018 · cited in 4 Washington opinions naming this issue, 2020–2025
2 sentences

2025To establish a bona fide dispute, the employer must show that (1) the employer had a subjective “genuine belief in the dispute at the time of the wage violation” and (2) “[the] dispute must be objectively reasonable—that is, the issue must be fairly debatable.” Hill, 191 Wn.2d at 562 (citations omitted) (internal quotation marks omitted).

2024To satisfy the subjective component, “[t]he employer must have a ‘genuine belief’ in the dispute at the time of the wage violation.” Hill, 191 Wn.2d at 562 (internal quotation marks omitted) (quoting Chelan County Sheriffs’ Ass’n v. Chelan County, 109 Wn.2d 282, 301 , 745 P.2d 1 (1987)).

24
Ellerman v. Centerpoint Prepress, Inc.green
wash · 2001 · cited in 4 Washington opinions naming this issue, 2014–2014
2 sentences

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

2014In Ellerman, we held that in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages. 143 Wn.2d at 522-23 (“[T]he statutes in question require more than the establishment of an agency relationship.

24
Rekhter v. Department of Social & Health Servicesgreen
wash · 2014 · cited in 2 Washington opinions naming this issue, 2014–2014
2 sentences

2014See Rekhter, 180 Wn.2d at 123 (explaining what plaintiff must show “in order to prevail on a wage claim” under RCW 49.52.050).

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

22
Chelan County Deputy Sheriffs' Ass'n v. County of Chelangreen
wash · 1987 · cited in 3 Washington opinions naming this issue, 2018–2024
2 sentences

2024To satisfy the subjective component, “[t]he employer must have a ‘genuine belief’ in the dispute at the time of the wage violation.” Hill, 191 Wn.2d at 562 (internal quotation marks omitted) (quoting Chelan County Sheriffs’ Ass’n v. Chelan County, 109 Wn.2d 282, 301 , 745 P.2d 1 (1987)).

2024To satisfy the subjective component, “[t]he employer must have a ‘genuine belief’ in the dispute at the time of the wage violation.” Hill, 191 Wn.2d at 562 (internal quotation marks omitted) (quoting Chelan County Sheriffs’ Ass’n v. Chelan County, 109 Wn.2d 282, 301 , 745 P.2d 1 (1987)).

13
Wingert v. Yellow Freight Systems, Inc.green
washctapp · 2000 · cited in 2 Washington opinions naming this issue, 2017–2024
2 sentences

2024App. at 698-99 (affirming trial court’s damages award issued in reliance on expert testimony establishing backpay damages for violation of meal and rest period provisions of WAC 296-126-092); Wingert, 104 Wn.

2017This court construes the statute liberally in order to “protect employee wages and assure payment.” Schilling v. Radio Holdings, Inc., 136 Wn.2d 152, 159 , 961 P.2d 371 (1998). ¶90 In Wingert v. Yellow Freight Systems, Inc., the court held that an employer’s failure to provide its employees with rest periods was a wage violation. 104 Wn.

12
Pellino v. Brink's, Inc.green
washctapp · 2011 · cited in 1 Washington opinions naming this issue, 2024–2024
1 sentence

2024App. at 360 (“violating the meal period requirement is a wage violation”); 24 No. 85502-6-I/25 Pellino, 164 Wn.

11
Ebling v. Gove's Cove, Inc.green
washctapp · 1983 · cited in 1 Washington opinions naming this issue, 2018–2018
2 sentences

2018See Chelan County, 109 Wash.2d at 301 , 745 P.2d 1 (quoting Ebling v. Gove's Cove, Inc., 34 Wash. App. 495 , 500, 663 P.2d 132 (1983) ).

2018See Chelan County, 109 Wash.2d at 301 , 745 P.2d 1 (quoting Ebling v. Gove's Cove, Inc., 34 Wash. App. 495 , 500, 663 P.2d 132 (1983) ).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
Schilling v. Radio Holdings, Inc. green
wash · 1998
2 sentences

2017This court construes the statute liberally in order to “protect employee wages and assure payment.” Schilling v. Radio Holdings, Inc., 136 Wn.2d 152, 159 , 961 P.2d 371 (1998). ¶90 In Wingert v. Yellow Freight Systems, Inc., the court held that an employer’s failure to provide its employees with rest periods was a wage violation. 104 Wn.

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

32014–2020
Schilling v. Radio Holdings, Inc. green
wash · 1998
2 sentences

2017This court construes the statute liberally in order to “protect employee wages and assure payment.” Schilling v. Radio Holdings, Inc., 136 Wn.2d 152, 159 , 961 P.2d 371 (1998). ¶90 In Wingert v. Yellow Freight Systems, Inc., the court held that an employer’s failure to provide its employees with rest periods was a wage violation. 104 Wn.

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

32014–2020
Lawrence Hill, Adam Wise, And Robert Miller, Res. v. Garda Cl Northwest, Inc., App. green
washctapp · 2017
2 sentences

2024If this court does not treat this as a wage violation, it is unclear what recourse the Plaintiffs would have. 198 Wn.

2018Hill, 198 Wash. App. at 364 -66 , 394 P.3d 390 . *573 ¶ 41 Whether an award of double exemplary damages under RCW 49.52.070 and an award of prejudgment interest result in an impermissible double recovery is a question of statutory interpretation that we review de novo.

22018–2024
Ellerman v. Centerpoint Prepress, Inc. green
wash · 2001
2 sentences

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

2014In Rekhter, we held that "in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages." Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.2d 514, 522-23 , 22 P.3d 795 (2001)).

22014–2014
Department of Labor & Industries v. Overnite Transportation Co. green
washctapp · 1992
2 sentences

2024App. 24 , 834 P.2d 638 (1992) controls the outcome here and held that DLI could initiate a lawsuit without assignment 15 No. 39459-0-III Dep’t L&I v. Cannabis Green, LLC, et al. of a wage claim.

2024Id. at 36 .

12024–2024
Department of Ecology v. Campbell & Gwinn, L.L.C. green
wash · 2002
2 sentences

2024Id.

2024Id.

12024–2024
Wingert v. Yellow Freight Systems, Inc. neutral
washctapp · 2001
1 sentence

2017App. 583, 588 , 13 P.3d 677 (2000).

12017–2017
LaCoursiere v. CamWest Development, Inc. green
wash · 2014
2 sentences

2017The statute does not define “wage,” but “another related wage statute, the Minimum Wage Act, chapter 49.46 RCW, broadly defines ‘wage’ as ‘compensation due to an employee by reason of employment.’” LaC oursiere v. CamWest Dev., Inc., 181 Wn.2d 734, 742 , 339 P.3d 963 (2014) (quoting RCW 49.46.010(7)).

2017The statute does not define “wage,” but “another related wage statute, the Minimum Wage Act, chapter 49.46 RCW, broadly defines ‘wage’ as ‘compensation due to an employee by reason of employment.’” LaC oursiere v. CamWest Dev., Inc., 181 Wn.2d 734, 742 , 339 P.3d 963 (2014) (quoting RCW 49.46.010(7)).

12017–2017
Iverson v. Snohomish County green
washctapp · 2003
1 sentence

2017It claims that the court made this distinction in Iverson v. Snohomish County, 117 Wn.

12017–2017
Morgan v. Kingen green
wash · 2009
1 sentence

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

12014–2014
Morgan v. Kingen green
wash · 2009
1 sentence

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

12014–2014
State v. Carter green
wash · 1943
2 sentences

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

2014Rekhter , like most of our chapter 49.52 RCW cases over its long history, never describes the act as the “wage rebate act.”See, e.g., Morgan v. Kingen, 166 Wn.2d 526 , 210 P.3d 995 (2009); Schilling v. Radio Holdings, Inc., 136 Wn.2d 152 , 961 P.2d 371 (1998); State v. Carter, 18 Wn.2d 590 , 140 P.2d 298 , 142 P.2d 403 (1943). f35 In Rekhter , we held that “in order to prevail on a wage claim, the employee must show that the party withholding the wages was both an agent and had control over the payment of wages.” Rekhter, 180 Wn.2d at 123 (citing Ellerman v. Centerpoint Prepress, Inc., 143 Wn.

12014–2014

Statutes the citing opinions construe

WA § Wash. Rev. Code § 49.52.070 (11) WA § Wash. Rev. Code § 49.52.050 (10) WA § Wash. Rev. Code § 49.46.090 (4) USC § 29u.s.c.185 (3) USC § 29u.s.c.201-219 (3) WA § Wash. Rev. Code § 49.46.010 (3) WA § Wash. Rev. Code § 49.46.020 (3) WA § Wash. Rev. Code § 49.48.030 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 91 (1984–2026) OR 39 (1955–2024) TX 17 (1954–2023) WI 17 (1954–2025) MT 16 (1986–2020) WA 11 (2014–2025) CT 10 (1960–2020) IN 9 (2001–2018) NH 9 (1998–2021) NY 9 (1969–2022) PA 8 (1914–2015) CO 8 (1989–2023) IA 8 (2000–2026) ID 8 (1996–2024) NJ 6 (1994–2026) IL 6 (1987–2023) MA 4 (2005–2014) LA 4 (1978–2025) OK 3 (2013–2014) MD 3 (2000–2016) WY 3 (1995–2021) NM 3 (1986–2016) AK 3 (1979–2021) FL 2 (1988–2025) KS 2 (2002–2012) VT 2 (2018–2025)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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