Wash. Rev. Code » Title 51 · Chapter 51.24
Revised Code of Washington

Wash. Rev. Code § 51.24.100 (2026)

✓ current as of May 2026
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The fact that the injured worker or beneficiary is entitled to compensation under this title shall not be pleaded or admissible in evidence in any third party action under this chapter. Any challenge of the right to bring such action shall be made by supplemental pleadings only and shall be decided by the court as a matter of law.
[ 1977 ex.s. c 85 s 8.]
Notes of Decisions
Cited in 7 cases (1 in the last 5 years), 2011–2021 · leading case: Gilmore v. Jefferson Cnty. Pub. Transp. Benefit Area, 415 P.3d 212 (Wash. 2018).
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Gilmore v. Jefferson Cnty. Pub. Transp. Benefit Area, 415 P.3d 212 (Wash. 2018). · cites it 9× “3d 1099 (2017)("[RCW 51.24.100] is unambiguous that an employee's receipt of benefits is inadmissible in a third party action").”
Francisco Entila Et Al., Appellants, v. Gerald Cook Et Al., Respondents, 360 P.3d 870 (Wash. Ct. App. 2015). · cites it 6× “RCW 51.24.100 and the collateral source rule bar consideration of this evidence in a third-party tort action.”
Entila v. Cook, 386 P.3d 1099 (Wash. 2017). “The statute provides: The fact that the injured worker or beneficiary is entitled to compensation under this title shall not be pleaded or admissible in evidence in any third party action under this chapter.”
Olsen v. Dep't of Labor & Indus., 161 Wash. App. 443 (Wash. Ct. App. 2011). “102 workers can receive some state benefits even if they may have a right or claim to benefits under federal maritime laws, but the court held this provision for “temporary, interim benefits” did not otherwise abrogate the exclusionary language of RCW 51.24.100. Gorman, 155…”
Olsen v. Washington State Dept. of Labor, 250 P.3d 158 (Wash. Ct. App. 2011). “102 workers can receive some state benefits even if they may have a right or claim to benefits under federal maritime laws, but the court held this provision for "temporary, interim benefits" did not otherwise abrogate the exclusionary language of RCW 51.”
Entila v. Cook (Wash. 2017). · cites it 2× “On appeal, Entila also argued that RCW 51.24.100 barred the trial court from considering his receipt of benefits in determining Cook's immunity.”
Am. Fam. Connect Prop. & Cas. Ins. Co. v. Huebner (W.D. Wash. 2021). “The Collateral Source Rule Does Not Apply 12 Huebner argues that the evidence of the Department of Labor and Industries payments 13 would be excluded at trial under both the general collateral source rule and a state Labor and 14 Industries statute, RCW 51.24.100. Dkt. # 11 at…”
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