Wash. Rev. Code » Title 41 · Chapter 41.06
Revised Code of Washington

Wash. Rev. Code § 41.06.220 (2026)

Reinstatement after appeal, guaranteed rights and benefits

✓ current as of May 2026
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Any employee, when fully reinstated after appeal, shall be guaranteed all employee rights and benefits, including back pay, sick leave, vacation accrual, retirement and OASDI credits.
[ 2011 1st sp.s. c 43 s 416; 1961 c 1 s 22 (Initiative Measure No. 207, approved November 8, 1960).]

Notes:

Effective date—Purpose—2011 1st sp.s. c 43: See notes following RCW 43.19.003.
Notes of Decisions
Cited in 12 cases, 1978–2014 · leading case: Reninger v. State Dept. of Corr., 951 P.2d 782 (Wash. 1998).
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Reninger v. State Dept. of Corr., 951 P.2d 782 (Wash. 1998). · cites it 2× “RCW 41.06.220. "Any employee, when fully reinstated after appeal, shall be guaranteed all employee rights and benefits, including back pay, sick leave, vacation accrual, retirement and OASDI credits as provided for in RCW 41.”
Reninger v. Dep't of Corr., 134 Wash. 2d 437 (Wash. 1998). · cites it 2× “RCW 41.06.220. “Any employee, when *453 fully reinstated after appeal, shall be guaranteed all employee rights and benefits, including back pay, sick leave, vacation accrual, retirement and OASDI credits as provided for in RCW 41.”
Trachtenberg v. Dep't of Corr., 93 P.3d 217 (Wash. Ct. App. 2004). · cites it 4× “As a result, by operation of RCW 41.06.220, Trachtenberg was entitled to back pay.”
Cohn v. Dep't of Corr., 895 P.2d 857 (Wash. Ct. App. 1995). · cites it 3× “, 13 this court held that RCW 41.06.220(2) did not waive the State’s sovereign immunity and did not leave the State liable for interest on back pay to a reinstated employee.”
Adams v. Dep't of Soc. & Health Servs., 683 P.2d 1133 (Wash. Ct. App. 1984). · cites it 2× “The sole issue raised by this appeal is the meaning of "back pay" as used in RCW 41.06.220(2). This statute provides: Any employee, when fully reinstated after appeal, shall be guaranteed all employee rights and benefits, including back pay, sick leave, vacation accrual,…”
Giles v. Dep't of Soc. & Health Servs., 583 P.2d 1213 (Wash. 1978). “RCW 41.06.220(2). Next, a constitutional challenge.”
Dunaway v. Dep't of Soc. & Health Servs., 579 P.2d 362 (Wash. 1978). · cites it 2× “170? (2) Where a dismissed employee is reinstated by the Personnel Board to the same position, but is ordered suspended for 5 months, has he been "fully reinstated" within the meaning of RCW 41.06.220(2), so as to be guaranteed "all employee rights and benefits"? *114 The…”
McIntyre v. Washington State Patrol, 141 P.3d 75 (Wash. Ct. App. 2006). “¶17 Trachtenberg does not apply because Trachtenberg was seeking attorney fees even though, as a civil service employee, he was entitled only to certain enumerated remedies, e.”
Kringel v. Dep't of Soc. & Health Servs., 733 P.2d 592 (Wash. Ct. App. 1987). “The judge therefore ordered that they be reinstated with all employee rights and benefits pursuant to RCW 41.06.220(2). No appeal was taken from that order.”
Kringel v. Dep't of Soc. & Health Servs., 726 P.2d 58 (Wash. Ct. App. 1986). · cites it 3× “—Is the State liable for interest on an award of back pay to a reinstated employee, made under RCW 41.06.220(2)? We hold that sovereign immunity protects the State from such liability, and reverse a superior court order to the contrary.”
City of Medina v. Skinner, 336 P.3d 1172 (Wash. Ct. App. 2014). “RCW 41.06.220(2) was enacted by initiative in 1961.”
City Of Medina v. Roger Skinner (Wash. Ct. App. 2014). “RCW 41.06.220(2) was enacted by initiative in 1961.”
— Wash. Rev. Code § 41.06.220(2) — 9 cases
Cohn v. Dep't of Corr., 895 P.2d 857 (Wash. Ct. App. 1995). “, 13 this court held that RCW 41.06.220(2) did not waive the State’s sovereign immunity and did not leave the State liable for interest on back pay to a reinstated employee.”
Adams v. Dep't of Soc. & Health Servs., 683 P.2d 1133 (Wash. Ct. App. 1984). “The sole issue raised by this appeal is the meaning of "back pay" as used in RCW 41.06.220(2). This statute provides: Any employee, when fully reinstated after appeal, shall be guaranteed all employee rights and benefits, including back pay, sick leave, vacation accrual,…”
Trachtenberg v. Dep't of Corr., 93 P.3d 217 (Wash. Ct. App. 2004). “As a result, by operation of RCW 41.06.220, Trachtenberg was entitled to back pay.”
Giles v. Dep't of Soc. & Health Servs., 583 P.2d 1213 (Wash. 1978). “RCW 41.06.220(2). Next, a constitutional challenge.”
Dunaway v. Dep't of Soc. & Health Servs., 579 P.2d 362 (Wash. 1978). “170? (2) Where a dismissed employee is reinstated by the Personnel Board to the same position, but is ordered suspended for 5 months, has he been "fully reinstated" within the meaning of RCW 41.06.220(2), so as to be guaranteed "all employee rights and benefits"? *114 The…”
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