Revised Code of Washington
Wash. Rev. Code § 51.32.020 (2026)
Who not entitled to compensation
✓ current as of May 2026
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If injury or death results to a worker from the deliberate intention of the worker himself or herself to produce such injury or death, or while the worker is engaged in the attempt to commit, or the commission of, a felony, neither the worker nor the widow, widower, child, or dependent of the worker shall receive any payment under this title.
If injury or death results to a worker from the deliberate intention of a beneficiary of that worker to produce the injury or death, or if injury or death results to a worker as a consequence of a beneficiary of that worker engaging in the attempt to commit, or the commission of, a felony, the beneficiary shall not receive any payment under this title.
An invalid child, while being supported and cared for in a state institution, shall not receive compensation under this chapter.
No payment shall be made to or for a natural child of a deceased worker and, at the same time, as the stepchild of a deceased worker.
[ 1995 c 160 s 2; 1977 ex.s. c 350 s 39; 1971 ex.s. c 289 s 42; 1961 c 23 s 51.32.020. Prior: 1957 c 70 s 27; prior: (i) 1927 c 310 s 5, part; 1919 c 131 s 5, part; 1911 c 74 s 6, part; RRS s 7680, part. (ii) 1949 c 219 s 1, part; 1947 c 246 s 1, part; 1929 c 132 s 2, part; 1927 c 310 s 4, part; 1923 c 136 s 2, part; 1919 c 131 s 4, part; 1917 c 28 s 1, part; 1913 c 148 s 1, part; 1911 c 74 s 5, part; Rem. Supp. 1949 s 7679, part.]
Notes:
Application—1995 c 160 ss 2 and 3: "Sections 2 and 3 of this act shall apply from July 23, 1995, without regard to the date of injury or the date of filing a claim." [ 1995 c 160 s 8.]
Notes of Decisions
Cited in 18
cases, 1960–2020 · leading case: Dep't of Labor & Indus. v. Rowley, 378 P.3d 139 (Wash. 2016).
Dep't of Labor & Indus. v. Rowley, 378 P.3d 139 (Wash. 2016). “RCW 51.32.020. Rowley filed a notice of appeal to the Board of Industrial Insurance Appeals (Board).”
Dep't of Labor & Indus. v. Rowley, 340 P.3d 929 (Wash. Ct. App. 2014). “We must decide what burden of proof and standard of proof apply when the Department claims the felony payment bar of RCW 51.32.020 prevents a worker from receiving benefits for an injury sustained in the course of employment.”
Willoughby v. Dep't of Labor & Indus., 147 Wash. 2d 725 (Wash. 2002). “RCW 51.32.020 (barring payment where a worker’s injuries are self inflicted).”
Schwab v. Dep't of Labor & Indus., 459 P.2d 1 (Wash. 1969). “In this connection RCW 51.32.020, in pertinent part, provides that the widow of an injured workman is not entitled to a pension under the act “If .”
Klossner v. San Juan Cnty., 605 P.2d 330 (Wash. 1980). “050; RCW 51.32.020,.025. The wrongful death and survival statutes, unlike those statutory provisions cited by respondent, contain no mention of stepchildren.”
Flavorland Indus., Inc. v. Schumacker, 647 P.2d 1062 (Wash. Ct. App. 1982). “520 and such felonious conduct, while in the scope of employment, operated to exclude him from the coverage of *432 the worker's compensation statute pursuant to RCW 51.32.020. RCW 46.61.520 provides in pertinent part: (1) When the death of any person shall ensue within three…”
Dep't of Labor & Indus. v. Shirley, 288 P.3d 390 (Wash. Ct. App. 2012). “RCW 51.32.020 precludes benefits to a worker or his beneficiaries “[i]f injury or death results to a worker from the deliberate intention of the worker himself or herself to produce such injury or death____” This provision acts as “a statutory bar between cause and proximate…”
Mercer v. Dep't of Labor & Indus., 442 P.2d 1000 (Wash. 1968). “RCW 51.32.020. The supervisor of claims dismissed the plaintiff’s claim and she appealed to the Board of Industrial Insurance Appeals.”
Hunt v. King Cnty., 481 P.2d 593 (Wash. Ct. App. 1971). “RCW 51.32.020 is a defense to such a claim “if .”
Dep't of Labor & Indus. v. Baker, 786 P.2d 821 (Wash. Ct. App. 1990). “050(6), under which the Board granted benefits, was overridden by RCW 51.32.020, which, the court found, bars all benefits following death by suicide.”
Winston v. Richard W. Wines, Inc., 351 P.2d 929 (Wash. 1960). “On January 9,1956, the supervisor of industrial *193 insurance issued an order rejecting the claim on the basis that, at the time of the injury, appellant was not in the course of his employment and therefore was not entitled to benefits under the provisions of RCW 51.32.020…”
Dep't of Labor & Indus. v. Rowley (Wash. 2016). “RCW 51.32.020. Rowley filed a notice of appeal to the Board of Industrial Insurance Appeals (Board).”
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