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

Wash. Rev. Code § 49.32.070 (2026)

Responsibility of associations

✓ current as of May 2026
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No officer or member of any association or organization, and no association or organization participating or interested in a labor dispute, shall be held responsible or liable in any court of the state of Washington for the unlawful acts of individual officers, members, or agents, except upon clear proof of actual participation in, or actual authorization of, such acts, or of ratification of such acts after actual knowledge thereof.
[ 1933 ex.s. c 7 s 6; RRS s 7612-6.]
Notes of Decisions
Cited in 8 cases (1 in the last 5 years), 1963–2022 · leading case: Buchanan v. Int'l Bhd. of Teamsters, Chauffeurs, Warehousemen & Helpers, 617 P.2d 1004 (Wash. 1980).
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Buchanan v. Int'l Bhd. of Teamsters, Chauffeurs, Warehousemen & Helpers, 617 P.2d 1004 (Wash. 1980). · cites it 46× “Plaintiff, not a union member, drove a delivery truck across the picket lines. He alleges that he was severely beaten by the individual union member defendants.”
Titus v. Tacoma Smeltermen's Union Local No. 25, 383 P.2d 504 (Wash. 1963). · cites it 9× “They rely on RCW 49.32.070, which states: “No officer or member of any association or organization, and no association or organization participating or interested in a labor dispute, shall be held responsible or liable in any court of the state of Washington for the unlawful…”
Dep't of Labor & Indus. v. Rowley, 378 P.3d 139 (Wash. 2016). “2d 1306 (1983) (RCW 49.32.070 “requires clear proof of union participation in, authorization of, or ratification of, contemptuous acts .”
Premium Distrib. Co. v. Int'l Bhd. of Teamsters Union Local 174, 664 P.2d 1306 (Wash. Ct. App. 1983). · cites it 4× “The Union contends that the evidence was insufficient to support a finding of its contempt liability under the "clear proof" standard of RCW 49.32.070. 1 It also contends that the evidence was insufficient to support the damage award.”
Marshall's Constr., Inc. v. Local No. 549 of United Ass'n of Journeymen, 443 P.2d 529 (Wash. 1968). · cites it 3× “736) RCW 49.32.070 is identical with section 6 of the Norris-LaGuardia Act (see note 2), if you substitute “any court of the state” of Washington for “any court of the United States.”
Dep't of Labor & Indus. v. Rowley (Wash. 2016). “2d 1306 (1983) (RCW 49.32.070 "requires clear proof of union participation in, authorization of, or ratification of, contemptuous acts .”
Dep't of Labor & Indus. v. Rowley (Wash. 2016). “2d 1306 (1983) (RCW 49.32.070 "requires clear proof of union participation in, authorization of, or ratification of, contemptuous acts .”
Brock Maslonka, et ux v. Pub. Util. Dist. No. 1 of Pend Oreille Cnty. (Wash. Ct. App. 2022). “Premium Distributing held that use of the term “clear proof” in RCW 49.32.070 meant an intermediate burden of proof “more than 25 No.”
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