Revised Code of Washington
Wash. Rev. Code § 51.16.155 (2026)
✓ current as of May 2026
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In every case where an employer insured with the state fails or refuses to file any report of payroll required by the department and fails or refuses to pay the premiums due on such unreported payroll, the department shall have authority to estimate such payroll and the premiums due thereon and collect premiums on the basis of such estimate.
If the report required and the premiums due thereon are not made within ten days from the mailing of such demand by the department, which shall include the amount of premiums estimated by the department, the employer shall be in default as provided by this title and the department may have and recover judgment, warrant, or file liens for such estimated premium or the actual premium, whichever is greater.
The director or the director's designee may compromise the amount of premiums estimated by the department, whether reduced to judgment or otherwise, arising under this title if collection of the premiums estimated by the department would be against equity and good conscience.
Notes:
Notes of Decisions
Cited in 8
cases (1 in the last 5 years), 1986–2021 · leading case: R & G Probst v. Dept. of Labor & Indus., 88 P.3d 413 (Wash. Ct. App. 2004).
R & G Probst v. Dept. of Labor & Indus., 88 P.3d 413 (Wash. Ct. App. 2004). “Because Diamond failed to provide requested information or cooperate in the audit, Doellinger followed RCW 51.16.155 [5] and estimated Diamond's premiums based on DOL and SPI records.”
R&G Probst v. Dep't of Labor & Indus., 121 Wash. App. 288 (Wash. Ct. App. 2004). “Because Diamond failed to provide requested information or cooper *292 ate in the audit, Doellinger followed RCW 51.16.155 5 and estimated Diamond’s premiums based on DOL and SPI records.”
Probst v. Dep't of Labor & Indus., 155 Wash. App. 908 (Wash. Ct. App. 2010). “Because Probst refused to cooperate with the audit, L&I estimated the premiums owed based on Department of Licensing (DOL) and SPI records as allowed under RCW 51.16.155. 2 Probst I, 121 Wn. App. at 291-92 .”
Delagrave v. Emp. Sec. Dep't, 111 P.3d 879 (Wash. Ct. App. 2005). “102 (waiver of overpayment by L&I to maritime workers due to overlap of federal benefits); RCW 51.16.155 (compromise in amount of employer L&I premium arrearages); RCW 51.”
Probst v. Dep't of Labor & Indus., 230 P.3d 271 (Wash. Ct. App. 2010). “Because Probst refused to cooperate with the audit, L & I estimated the premiums owed based on Department of Licensing (DOL) and SPI records as allowed under RCW 51.16.155. [2] Probst I, 121 Wash.App.”
Dolman v. Dep't of Labor & Indus., 716 P.2d 852 (Wash. 1986). “RCW 51.16.155. *566 It need not rely upon self-reporting by the employer.”
Delagrave v. Emp. Sec. Dept. of State, 111 P.3d 879 (Wash. Ct. App. 2005). “102 (waiver of overpayment by L & I to maritime workers due to overlap of federal benefits); RCW 51.16.155 (compromise in amount of employer L & I premium arrearages); RCW 51.”
Chris Jones & Katrina Jones, V. Dept. Of L&i (Wash. Ct. App. 2021). “An employer may appeal this assessment to the Board, and, once administrative remedies are exhausted, the employer may appeal to the superior court.”
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