Revised Code of Washington

Wash. Rev. Code § 49.32.030 (2026)

Undertakings and promises unenforceable

✓ current as of May 2026

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Any undertaking or promise, such as is described in this section, or any other undertaking or promise in conflict with the public policy declared in RCW 49.32.020, is hereby declared to be contrary to the public policy of the state of Washington, shall not be enforceable in any court of the state of Washington, and shall not afford any basis for the granting of legal or equitable relief by any such court, including specifically the following:

Every undertaking or promise hereafter made, whether written or oral, express or implied, constituting or contained in any contract or agreement of hiring or employment between any individual, firm, company, association, or corporation and any employee or prospective employee of the same, whereby:

(1) Either party to such contract or agreement undertakes or promises not to join, become, or remain a member of any labor organization or of any employer organization; or

(2) Either party to such contract or agreement undertakes or promises that he or she will withdraw from an employment relation in the event that he or she joins, becomes, or remains a member of any labor organization or of any employer organization.

[ 2010 c 8 s 12029; 1933 ex.s. c 7 s 3; RRS s 7612-3.]

Notes of Decisions

Cited in 4 cases, 1965–2019 · leading case: Krystad v. Lau, 400 P.2d 72 (Wash. 1965).

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Krystad v. Lau, 400 P.2d 72 (Wash. 1965). · cites it 4× “e little Norris-LaGuardia Act conferred no substantive rights, that § 2 thereof invoked by appellants is merely a declaration of policy, and that the entire act is fundamentally a limitation on the power of the court to grant injunctions in cases growing out of labor disputes…”

Plumbers & Steamfitters Union Local 598 v. Washington Pub. Power Supply Sys., 724 P.2d 1030 (Wash. Ct. App. 1986). · cites it 2× “"(9) Advising, urging, or otherwise causing or inducing without fraud or violence the acts heretofore specified, regardless of any such undertaking or promise as is described in RCW 49.32.030." RCW 49.36.010: "Unions legalized.”

Int'l Union of Operating Engineers Local No. 286 v. Sand Point Country Club, 519 P.2d 985 (Wash. 1974). · cites it 2× “32, commonly referred to as Washington’s little Norris-LaGuardia act, makes “yellow-dog” contracts unenforceable (RCW 49.32.030). It also places limitations upon the injunctive powers of the courts in dealing with labor disputes.”

Kelley v. The Boeing Co. (W.D. Wash. 2019). · cites it 2× “58, a 2 Washington statute prohibiting “employers from retaliating against employees who bring 3 discrimination to light.”

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