Revised Code of Washington

Wash. Rev. Code § 51.04.010 (2026)

✓ current as of May 2026
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The common law system governing the remedy of workers against employers for injuries received in employment is inconsistent with modern industrial conditions. In practice it proves to be economically unwise and unfair. Its administration has produced the result that little of the cost of the employer has reached the worker and that little only at large expense to the public. The remedy of the worker has been uncertain, slow and inadequate. Injuries in such works, formerly occasional, have become frequent and inevitable. The welfare of the state depends upon its industries, and even more upon the welfare of its wage worker. The state of Washington, therefore, exercising herein its police and sovereign power, declares that all phases of the premises are withdrawn from private controversy, and sure and certain relief for workers, injured in their work, and their families and dependents is hereby provided regardless of questions of fault and to the exclusion of every other remedy, proceeding or compensation, except as otherwise provided in this title; and to that end all civil actions and civil causes of action for such personal injuries and all jurisdiction of the courts of the state over such causes are hereby abolished, except as in this title provided.
[ 1977 ex.s. c 350 s 1; 1972 ex.s. c 43 s 1; 1961 c 23 s 51.04.010. Prior: 1911 c 74 s 1; RRS s 7673.]
Notes of Decisions
Cited in 336 cases (32 in the last 5 years), 1953–2026 · leading case: Flanigan v. Dep't of Labor & Indus., 869 P.2d 14 (Wash. 1994).
Flanigan v. Dep't of Labor & Indus., 869 P.2d 14 (Wash. 1994). · cites it 14× “The issue in common is whether the Department's right of reimbursement extends to a surviving spouse's third party recovery for loss of consortium.”
Seattle-First Nat'l Bank v. Shoreline Concrete Co., 588 P.2d 1308 (Wash. 1978). · cites it 10× “RCW 51.04.010 provides in part: The state of Washington .”
Holbrook v. Weyerhaeuser Co., 822 P.2d 271 (Wash. 2003). · cites it 14× “The purpose of the act, set forth at RCW 51.04.010, is lengthy but warrants full consideration.”
Reese v. Sears, Roebuck & Co., 731 P.2d 497 (Wash. 1987). · cites it 8× “Their appeals have been consolidated because they raise an identical question of law: whether the exclusive remedy provision of the Industrial Insurance Act (IIA), RCW 51.04.010, bars employee actions against their employers for disability discrimination under the Law Against…”
Wilmot v. Kaiser Aluminum & Chem. Corp., 821 P.2d 18 (Wash. 1991). · cites it 5× “(Some italics ours.) Defendant Kaiser maintains, though, that the placement of RCW 51.”
Vallandigham v. Clover Park Sch. Dist. No. 400, 154 Wash. 2d 16 (Wash. 2005). · cites it 3× “While Washington’s Industrial Insurance Act (IIA), Title 51 RCW, generally precludes employee recovery out *18 side of the workers’ compensation scheme established by that statute, RCW 51.04.010, the legislature has created a limited exception, permitting tort recovery if an…”
Vallandigham v. Clover Park Sch. Dist., 109 P.3d 805 (Wash. 2005). · cites it 3× “While Washington's Industrial Insurance Act (IIA), Title 51 RCW, generally precludes employee recovery outside of the workers' compensation scheme established by that statute, RCW 51.04.010, the legislature has created a limited exception, permitting tort recovery if an employer…”
Minton v. Ralston Purina Co., 47 P.3d 556 (Wash. 2002). · cites it 6× “010 and RCW 51.04.010, and that Ralston, as a parent corporation, was not liable to Minton for the torts of its wholly owned subsidiary.”
Newby v. Gerry, 690 P.2d 603 (Wash. Ct. App. 1984). · cites it 12× “Newby alleged that, inter alia, Gerry intentionally assaulted him.”
Olch v. Pac. Press & Shear Co., 573 P.2d 1355 (Wash. Ct. App. 1978). · cites it 8× “is hereby provided regardless of questions of fault and to the exclusion of every other remedy, proceeding or compensation, except as otherwise provided in this title; and to that end all civil actions and civil causes of action for such personal injuries and all jurisdiction of…”
Birklid v. Boeing Co., 904 P.2d 278 (Wash. 1995). · cites it 4× “In a case involving a conflict between the exclusivity provision of Washington's Industrial Insurance Act, RCW 51.04.010, and the deliberate intent to injure exception found in RCW 51.”
Birklid v. Boeing Co., 11 I.E.R. Cas. (BNA) 97 (Wash. 1995). · cites it 4× “In a case involving a conflict between the exclusivity provision of Washington’s Industrial Insurance Act, RCW 51.04.010, and the deliberate intent to injure exception found in RCW 51.”
— Wash. Rev. Code § 51.04.010(3) — 1 case
Kerr v. Olson, 798 P.2d 819 (Wash. Ct. App. 1990).
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