Wash. Rev. Code » Title 50 · Chapter 50.32
Revised Code of Washington

Wash. Rev. Code § 50.32.097 (2026)

Applicability of finding, determination, etc., to other action

✓ current as of May 2026
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Any finding, determination, conclusion, declaration, or final order made by the commissioner, or his or her representative or delegate, or by an appeal tribunal, administrative law judge, reviewing officer, or other agent of the department for the purposes of Title 50 RCW, shall not be conclusive, nor binding, nor admissible as evidence in any separate action outside the scope of Title 50 RCW between an individual and the individual's present or prior employer before an arbitrator, court, or judge of this state or the United States, regardless of whether the prior action was between the same or related parties or involved the same facts or was reviewed pursuant to RCW 50.32.120.
[ 1988 c 28 s 1.]
Notes of Decisions
Cited in 11 cases (1 in the last 5 years), 1995–2026 · leading case: Smith v. Emp. Sec. Dep't, 155 Wash. App. 24 (Wash. Ct. App. 2010).
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Smith v. Emp. Sec. Dep't, 155 Wash. App. 24 (Wash. Ct. App. 2010). · cites it 2× “RCW 50.32.097; see Christensen v. Grant County Hosp.”
Christensen v. Grant Cnty. Hosp. Dist. No. 1, 96 P.3d 957 (Wash. 2004). “RCW 50.32.097, for example, provides that *315 any finding or other determination by the Employment Security Department “shall not be conclusive, nor binding, nor admissible as evidence” in any action outside Title 50 RCW.”
Smith v. Emp. Sec. Dept., 226 P.3d 263 (Wash. Ct. App. 2010). · cites it 2× “RCW 50.32.097; see Christensen v. Grant County Hosp.”
Reninger v. Dept. of Corr., 901 P.2d 325 (Wash. Ct. App. 1995). “RCW 50.32.097 (emphasis added). Finally, the disparity of relief was not an adequate basis to exclude the PAB findings.”
Carver v. State, 197 P.3d 678 (Wash. Ct. App. 2008). “In the area of employment security, for instance, RCW 50.32.097 provides: Any finding, determination, conclusion, declaration, or final order made by the commissioner, or his or her representative or delegate, or by an appeal tribunal, administrative law judge, reviewing…”
Carver v. State, 147 Wash. App. 567 (Wash. Ct. App. 2008). “097 provides: Any finding, determination, conclusion, declaration, or final order made by the commissioner, or his or her representative or *574 delegate, or by an appeal tribunal, administrative law judge, reviewing officer, or other agent of the department for the purposes of…”
Christensen v. Grant Cnty. Hosp. Dist., 96 P.3d 957 (Wash. 2004). “RCW 50.32.097, for example, provides that any finding or other determination by the Employment Security Department "shall not be conclusive, nor binding, nor admissible as evidence" in any action outside Title 50 RCW.”
Reninger v. Dep't of Corr., 79 Wash. App. 623 (Wash. Ct. App. 1995). “*637 RCW 50.32.097 (emphasis added). Finally, the disparity of relief was not an adequate basis to exclude the PAB findings.”
Christensen v. Grant Cnty. Hosp. Dist. No. 1, 60 P.3d 99 (Wash. Ct. App. 2002). “In response, Samaritan successfully argued RCW 50.32.097 precluded Mr. Christensen from relying on ESD decisions and orders in litigating a matter outside the unemployment compensa *584 tion area.”
Christensen v. Grant Cnty. Hosp. Dist., 60 P.3d 99 (Wash. Ct. App. 2002). “In response, Samaritan successfully argued RCW 50.32.097 precluded Mr. Christensen from relying on ESD decisions and orders in litigating a matter outside the unemployment compensation area.”
Eric W. Allen, V. State Of Washington Dep't Of Labor & Indus. (Wash. Ct. App. 2026). “But RCW 50.32.097 provides that findings, determinations, conclusions, or final orders issued by ESD "shall not be conclusive, nor binding, nor admissible as evidence in any separate action outside the scope of Title 50 RCW between an individual and the individual’s employer.”
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