Revised Code of Washington
Wash. Rev. Code § 49.48.082 (2026)
✓ current as of May 2026
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(1) "Citation" means a written determination by the department that a wage payment requirement has been violated.
(2) "Department" means the department of labor and industries.
(3) "Determination of compliance" means a written determination by the department that wage payment requirements have not been violated.
(4) "Director" means the director of the department of labor and industries, or the director's authorized representative.
(5) "Employee" has the meaning provided in: (a) RCW 49.46.010 for purposes of a wage payment requirement set forth in RCW 49.46.020 or 49.46.130; and (b) RCW 49.12.005 for purposes of a wage payment requirement set forth in RCW 49.48.010, 49.52.050, or 49.52.060.
(6) "Employer" has the meaning provided in RCW 49.46.010 for purposes of a wage payment requirement set forth in RCW 49.46.020, 49.46.130, 49.48.010, 49.52.050, or 49.52.060.
(7) "Notice of assessment" means a written notice by the department that, based on a citation, the employer shall pay the amounts assessed under RCW 49.48.083.
(8) "Repeat willful violator" means any employer that has been the subject of a final and binding citation and notice of assessment for a willful violation of a wage payment requirement within three years of the date of issue of the most recent citation and notice of assessment for a willful violation of a wage payment requirement.
(9) "Successor" means any person to whom an employer quitting, selling out, exchanging, or disposing of a business sells or otherwise conveys in bulk and not in the ordinary course of the employer's business, more than 50 percent of the property, whether real or personal, tangible or intangible, of the employer's business.
(10) "Wage" has the meaning provided in RCW 49.46.010.
(11) "Wage complaint" means a complaint from an employee to the department that asserts that an employer has violated one or more wage payment requirements and that is reduced to writing.
(12) "Wage payment requirement" means a wage payment requirement set forth in RCW 49.46.020, 49.46.130, 49.48.010, 49.52.050, 49.52.060, or 49.46.380, and any related rules adopted by the department.
(13) "Willful" means a knowing and intentional action that is neither accidental nor the result of a bona fide dispute, as evaluated under the standards applicable to wage payment violations under RCW 49.52.050(2).
Notes:
Captions not law—2006 c 89: "Captions used in this act are not any part of the law." [ 2006 c 89 s 8.]
Notes of Decisions
Cited in 11
cases (6 in the last 5 years), 2013–2025 · leading case: Dep't of Labor & Indus. v. Cannabis Green, LLC (Wash. Ct. App. 2024).
Dep't of Labor & Indus. v. Cannabis Green, LLC (Wash. Ct. App. 2024). “The WPA In 2006, the legislature enacted a new process of handling wage violations known as the WPA, currently codified at RCW 49.48.082 through .087. See LAWS OF 2006, ch.”
Gca Prod. Servs., Inc. v. Abdik Adir Hassan (Wash. Ct. App. 2021). “060, and any related rules adopted by the department.”). In particular, RCW 49.52.050(2) provides that an employer is guilty of a misdemeanor if it “[w]ilfully and with intent to deprive the employee of any part of [their] wages, shall pay any employee a lower wage than the wage…”
Gca Prod. Servs., Inc., V. Abdik Adir Hassan (Wash. Ct. App. 2021). “In particular, RCW 49.52.050(2) provides that an employer is guilty of a misdemeanor if it “[w]ilfully and with intent to deprive the employee of any part of [their] wages, shall pay any employee a lower wage than the wage such employer is obligated to pay such employee by any…”
Jeremy J. Moberg v. Terraqua, Inc. (Wash. Ct. App. 2017). “RCW 49.48.082(5)(b). Under the Industrial Welfare Act, chapter 49.”
Karl Kersteter, V. Concrete Sch. Dist. (Wash. Ct. App. 2022). “This definition is also applied in RCW 49.48.082(10). The plain language does not include benefits as part of wages.”
Blair v. Soap Lake Nat. Spa & Resort LLC (E.D. Wash. 2020). “Code 20 §§ 49.48.082(11), .083–.087; Winter v. Toyota of Vancouver USA, Inc.”
Daniels v. sia Abrasives Inc USA (W.D. Wash. 2019). “010(4) (minimum wage statute defining “employer” as “any individual, partnership, association, corporation, business trust, or 4 any person or group of persons acting directly or indirectly in the interest of an employer in relation to an employee”); RCW 49.48.082 (unpaid wage…”
Ranko v. Gulf Marine Prods. Co Inc (W.D. Wash. 2020). “050, an employer who “willfully and with intent to deprive the employee of any 20 part of his or her wages, shall pay any employee a lower wage than the wage such 21 employer is obligated to pay such employee by .”
Gaspar v. Turn Tech. Inc (W.D. Wash. 2024). “[010](7), incorporated by RCW 49.48.082, ‘wage’ means ‘compensation due to an employee by reason of employment, payable in legal tender,’ or ‘checks 2 on banks convertible into cash.”
Dep't of Lab. & Indus. v. Cannabis Green, LLC, 569 P.3d 303 (Wash. 2025). “” RCW 49.48.082(11). 5 Upon receipt of a wage complaint, L&I “shall” investigate and, “[u]nless otherwise resolved,” within 60 days shall either issue a citation and notice of assessment or issue a determination of compliance.”
Janee' Wolf v. IDA Mktg. Servs., Inc. (Wash. Ct. App. 2013). “"A bona fide dispute is a 'fairly debatable' dispute over whether all or a 2 See RCW 49.48.082(5) (defining employee). 9 No.”
— Wash. Rev. Code § 49.48.082(10) — 1 case
Karl Kersteter, V. Concrete Sch. Dist. (Wash. Ct. App. 2022). “This definition is also applied in RCW 49.48.082(10). The plain language does not include benefits as part of wages.”
— Wash. Rev. Code § 49.48.082(11) — 5 cases
Gca Prod. Servs., Inc. v. Abdik Adir Hassan (Wash. Ct. App. 2021). “060, and any related rules adopted by the department.”). In particular, RCW 49.52.050(2) provides that an employer is guilty of a misdemeanor if it “[w]ilfully and with intent to deprive the employee of any part of [their] wages, shall pay any employee a lower wage than the wage…”
Gca Prod. Servs., Inc., V. Abdik Adir Hassan (Wash. Ct. App. 2021). “In particular, RCW 49.52.050(2) provides that an employer is guilty of a misdemeanor if it “[w]ilfully and with intent to deprive the employee of any part of [their] wages, shall pay any employee a lower wage than the wage such employer is obligated to pay such employee by any…”
Dep't of Labor & Indus. v. Cannabis Green, LLC (Wash. Ct. App. 2024). “The WPA In 2006, the legislature enacted a new process of handling wage violations known as the WPA, currently codified at RCW 49.48.082 through .087. See LAWS OF 2006, ch.”
Blair v. Soap Lake Nat. Spa & Resort LLC (E.D. Wash. 2020). “Code 20 §§ 49.48.082(11), .083–.087; Winter v. Toyota of Vancouver USA, Inc.”
Dep't of Lab. & Indus. v. Cannabis Green, LLC, 569 P.3d 303 (Wash. 2025). “” RCW 49.48.082(11). 5 Upon receipt of a wage complaint, L&I “shall” investigate and, “[u]nless otherwise resolved,” within 60 days shall either issue a citation and notice of assessment or issue a determination of compliance.”
— Wash. Rev. Code § 49.48.082(12) — 2 cases
Gca Prod. Servs., Inc. v. Abdik Adir Hassan (Wash. Ct. App. 2021). “060, and any related rules adopted by the department.”). In particular, RCW 49.52.050(2) provides that an employer is guilty of a misdemeanor if it “[w]ilfully and with intent to deprive the employee of any part of [their] wages, shall pay any employee a lower wage than the wage…”
Gca Prod. Servs., Inc., V. Abdik Adir Hassan (Wash. Ct. App. 2021). “In particular, RCW 49.52.050(2) provides that an employer is guilty of a misdemeanor if it “[w]ilfully and with intent to deprive the employee of any part of [their] wages, shall pay any employee a lower wage than the wage such employer is obligated to pay such employee by any…”
— Wash. Rev. Code § 49.48.082(5) — 1 case
Janee' Wolf v. IDA Mktg. Servs., Inc. (Wash. Ct. App. 2013). “"A bona fide dispute is a 'fairly debatable' dispute over whether all or a 2 See RCW 49.48.082(5) (defining employee). 9 No.”
— Wash. Rev. Code § 49.48.082(5)(b) — 1 case
Jeremy J. Moberg v. Terraqua, Inc. (Wash. Ct. App. 2017). “RCW 49.48.082(5)(b). Under the Industrial Welfare Act, chapter 49.”
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