Wash. Rev. Code » Title 49 · Chapter 49.32
Revised Code of Washington

Wash. Rev. Code § 49.32.020 (2026)

Policy enunciated

✓ current as of May 2026
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*** CHANGE IN 2026 *** (SEE 2471-S.SL) ***
In the interpretation of this chapter and in determining the jurisdiction and authority of the courts of the state of Washington, as such jurisdiction and authority are herein defined and limited, the public policy of the state of Washington is hereby declared as follows:
WHEREAS, Under prevailing economic conditions, developed with the aid of governmental authority for owners of property to organize in the corporate and other forms of ownership association, the individual unorganized worker is commonly helpless to exercise actual liberty of contract and to protect his or her freedom of labor, and thereby to obtain acceptable terms and conditions of employment, wherefore, though he or she should be free to decline to associate with his or her fellows, it is necessary that he or she have full freedom of association, self-organization, and designation of representatives of his or her own choosing, to negotiate the terms and conditions of his or her employment, and that he or she shall be free from interference, restraint, or coercion of employers of labor, or their agents, in the designation of such representatives or in self-organization or in other concerted activities for the purpose of collective bargaining or other mutual aid or protections; therefore, the following definitions of, and limitations upon, the jurisdiction and authority of the courts of the state of Washington are hereby enacted.
[ 2010 c 8 s 12028; 1933 ex.s. c 7 s 2; RRS s 7612-2.]
Notes of Decisions
Cited in 30 cases (1 in the last 5 years), 1954–2021 · leading case: Briggs v. Nova Servs., 213 P.3d 910 (Wash. 2009).
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Briggs v. Nova Servs., 213 P.3d 910 (Wash. 2009). · cites it 32× “After a hearing, the trial court denied the motion for continuance and granted the motion for summary judgment. ¶ 10 The Employees appealed and Division Three of the Court of Appeals affirmed on all grounds.”
Briggs v. Nova Servs., 166 Wash. 2d 794 (Wash. 2009). · cites it 31× “Regarding summary judgment, the court held that the Employees had not engaged in concerted activities protected under RCW 49.32.020 because the Employees’ concerns did not relate to a term or condition of employment.”
Bravo v. Dolsen Companies, 888 P.2d 147 (Wash. 1995). · cites it 28× “The suit was brought under RCW 49.32.020, which prohibits employers from interfering with, restraining or coercing employees in self-organization or other "concerted activities for the purpose of collective bargaining or other mutual aid or protections”.”
Briggs v. Nova Servs., 135 Wash. App. 955 (Wash. Ct. App. 2006). · cites it 17× “¶16 The Workers first contend Nova wrongfully terminated them for joining together to complain to the Board, violating a public policy allowing employees to join together and engage in “concerted activities” under RCW 49.32.020. Nova responds that the Workers inappropriately…”
Briggs v. Nova Servs., 147 P.3d 616 (Wash. Ct. App. 2006). · cites it 17× “¶ 16 The Workers first contend Nova wrongfully terminated them for joining together to complain to the Board, violating a public policy allowing employees to join together and engage in "concerted activities" under RCW 49.32.020. Nova responds that the Workers inappropriately…”
Pulcino v. Fed. Express Corp., 9 P.3d 787 (Wash. 2000). · cites it 12× “§§ 151-164 , and, if not preempted, then is subject to dismissal because RCW 49.32.020 prohibits union discrimination only when it is based upon an employee’s participation in specific, statutorily protected activities.”
Christensen v. Grant Cnty. Hosp. Dist. No. 1, 96 P.3d 957 (Wash. 2004). · cites it 5× “Neither party appealed the decision to superior court. In November 2000, Christensen filed suit in Grant County Superior Court, alleging that Samaritan discharged him in retaliation for his union activities in violation of public policy stated in RCW 49.”
Krystad v. Lau, 400 P.2d 72 (Wash. 1965). · cites it 18× “They refer to RCW 49.32.020, Laws of 1933, Ex. Ses., chapter 7, § 2, p.”
Int'l Union of Operating Engineers Local No. 286 v. Sand Point Country Club, 519 P.2d 985 (Wash. 1974). · cites it 14× “A single contention is made on appeal — that RCW 49.32.020 imposes upon employers an affirmative duty to bargain with representatives of their employees.”
Culinary Workers & Bartenders Union v. Gateway Cafe, Inc., 588 P.2d 1334 (Wash. 1979). · cites it 5× “Finally, appellants contend the public policy contained in RCW 49.32.020 prohibits agreements containing a provision *369 such as is involved in this case.”
Pulcino v. Fed. Express Corp., 972 P.2d 522 (Wash. Ct. App. 1999). · cites it 13× “But we agree with Pulcino that RCW 49.32.020 gives her a cause of action against FedEx for wrongful interference with organized workers, and the court erroneously limited her union discrimination theory to wrongful discharge.”
Kilb v. First Student Transp., LLC, 236 P.3d 968 (Wash. Ct. App. 2010). · cites it 5× “Kilb maintains he was fired for "refusing to commit the illegal acts of terminating pro-union employees and for not following the First Student management's directives regarding leading the anti-union efforts in the Gresham branch." Clerk's Papers at 6. ¶ 5 Kilb sued in Clark…”
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