Revised Code of Washington

Wash. Rev. Code § 49.52.080 (2026)

Presumption as to intent

✓ current as of May 2026

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The violations by an employer or any officer, vice principal, or agent of any employer of any of the provisions of subdivisions (3), (4), and (5) of RCW 49.52.050 shall raise a presumption that any deduction from or underpayment of any employee's wages connected with such violation was wilful.

[ 1939 c 195 s 4; RRS s 7612-24.]

Notes of Decisions

Cited in 3 cases (1 in the last 5 years), 1969–2024 · leading case: Hill v. Garda CL Nw., Inc., 424 P.3d 207 (Wash. 2018).

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Hill v. Garda CL Nw., Inc., 424 P.3d 207 (Wash. 2018). “2d 371 ) ); see also RCW 49.52.080 (presuming willfulness). But an employer defeats a showing of willful deprivation of wages if it shows there was a "bona fide" dispute about whether all or part of the wages were really due.”

Brandt v. Impero, 463 P.2d 197 (Wash. Ct. App. 1969). · cites it 2× “050; RCW 49.52.080. 1 The trial court, sitting without a jury, granted plaintiff judgment for unpaid wages, double damages and *680 attorneys’ fees.”

Virginia Mason Med. Ctr., V. Rheannon Androckitis (Wash. Ct. App. 2024). “3d 995 (2009)); see also RCW 49.52.080 (presuming willfulness). The court further instructed that an affirmative defense to a willful deprivation of wages can be raised in wage claims over which the employer and employees have a “‘bona fide’” or “‘fairly debatable’” dispute,…”

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