Wash. Rev. Code » Title 51 · Chapter 51.32
Revised Code of Washington

Wash. Rev. Code § 51.32.225 (2026)

✓ current as of May 2026
Find cases: SyfertCases citing this section WA-LEGapp.leg.wa.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
(1) For persons receiving compensation for temporary or permanent total disability under this title, the compensation shall be reduced by the department to allow an offset for social security retirement benefits payable under the federal social security, old age survivors, and disability insurance act, 42 U.S.C. This reduction shall not apply to any worker who is receiving permanent total disability benefits prior to July 1, 1986. This reduction does not apply to workers who had applied to receive social security retirement benefits prior to the date of their injury or to workers who were receiving social security benefits prior to their injury.
(2) Reductions for social security retirement benefits under this section shall comply with the procedures in RCW 51.32.220 (1) through (6) and with any other procedures established by the department to administer this section. For any worker whose entitlement to social security retirement benefits is immediately preceded by an entitlement to social security disability benefits, the offset shall be based on the formulas provided under 42 U.S.C. Sec. 424a. For all other workers entitled to social security retirement benefits, the offset shall be based on procedures established and determined by the department to most closely follow the intent of RCW 51.32.220.
(3) Any reduction in compensation made under chapter 58, Laws of 1986, shall be made before the reduction established in this section.
[ 2018 c 163 s 1; 2006 c 163 s 1; 1986 c 59 s 5.]

Notes:

Application—2018 c 163: "This act applies to claims with dates of injury on or after June 7, 2018." [ 2018 c 163 s 2.]
Effective date—1986 c 59 s 5: See note following RCW 51.32.090.
Notes of Decisions
Cited in 17 cases (2 in the last 5 years), 1993–2025 · leading case: Harris v. Dep't of Labor & Indus., 843 P.2d 1056 (Wash. 1993).
Sort: Relevance Newest Treatment
Harris v. Dep't of Labor & Indus., 843 P.2d 1056 (Wash. 1993). · cites it 114× “The appellant, Alice Harris, the widow of Jack Harris, challenges a reduction in her husband's workers' compensation benefits pursuant to RCW 51.32.225. RCW 51.32.225(1) provides for a reduction in workers' compensation benefits for those receiving Social Security retirement…”
Frazier v. Dep't of Labor & Indus., 3 P.3d 221 (Wash. Ct. App. 2000). · cites it 13× “He argues that because he received a lump sum disability payment rather than monthly benefits, he was not a person "receiving compensation" as RCW 51.32.225 uses that phrase and, thus, there was no statutory authorization for the deduction.”
Frazier v. Dep't of Labor & Indus., 101 Wash. App. 411 (Wash. Ct. App. 2000). · cites it 13× “He argues that because he received a lump sum disability payment rather than monthly benefits, he was not a person “receiving compensation” as RCW 51.32.225 uses that phrase and, thus, there was no statutory authorization for the deduction.”
Stuckey v. Dep't of Labor & Indus., 129 Wash. 2d 289 (Wash. 1996). · cites it 5× “Stuckey has turned 65, then the statute authorizing offset of his social security retirement benefits is RCW 51.32.225. At oral argument, counsel for Petitioners made arguments regarding RCW 51.”
Stuckey v. Dept. of Labor & Indus., 916 P.2d 399 (Wash. 1996). · cites it 5× “Stuckey has turned 65, then the statute authorizing offset of his social security retirement benefits is RCW 51.32.225. At oral argument, counsel for Petitioners made arguments regarding RCW 51.”
Birgen v. Dep't of Labor & Indus., 347 P.3d 503 (Wash. Ct. App. 2015). · cites it 2× “220 (Social Security disability benefits) or RCW 51.32.225 (Social Security retirement benefits) to offset Birgen’s workers’ compensation benefits.”
Doan v. State, Dept. of Labor & Indus., 178 P.3d 1074 (Wash. Ct. App. 2008). · cites it 14× “The trial court reversed the BIAA's decision, finding that because Doan had "not received a retroactive award of total disability benefits, or any benefits from which an offset can be taken under RCW 51.32.225, the Department did not have the authority to enter the August 26…”
Potter v. Dep't of Labor & Indus., 101 Wash. App. 399 (Wash. Ct. App. 2000). · cites it 6× “About six weeks after RCW 51.32.225 became effective on July 1, 1986, the Department issued an order reducing the claimant’s disability payments by the amount of Social Security retirement benefits he had been receiving.”
Doan v. Dep't of Labor & Indus., 143 Wash. App. 596 (Wash. Ct. App. 2008). · cites it 13× “The trial court reversed the BIIA’s decision, finding that because Doan had “not received a retroactive award of total disability benefits, or any benefits from which an offset can be taken under RCW 51.32.225, the Department did not have the authority to enter the August 26…”
Potter v. Dep't of Labor & Ind., 3 P.3d 229 (Wash. Ct. App. 2000). · cites it 6× “About six weeks after RCW 51.32.225 became effective on July 1, 1986, the Department issued an order reducing the claimant's disability payments by the amount of social security retirement benefits he had been receiving.”
Margaret West, V. State Of Wa, Dept Of L & I (Wash. Ct. App. 2023). · cites it 29× “But once they began receiving social security retirement benefits after reaching retirement age, DLI reduced their disability benefits based on RCW 51.32.225. 42 U.S.C § 424a(a) provides that if a person has not yet reached retirement age and is entitled to receive both social…”
Cena v. Dep't of Labor & Indus., 121 Wash. App. 915 (Wash. Ct. App. 2004). · cites it 2× “Cena acknowledges that the legislature established a setoff of social security benefits against persons receiving total disability when it adopted RCW 51.32.225 in 1986. But he claims that the setoff should be figured against total wages under RCW 51.”
Show all 17 citing cases →
— Wash. Rev. Code § 51.32.225(1) — 10 cases
Harris v. Dep't of Labor & Indus., 843 P.2d 1056 (Wash. 1993). “The appellant, Alice Harris, the widow of Jack Harris, challenges a reduction in her husband's workers' compensation benefits pursuant to RCW 51.32.225. RCW 51.32.225(1) provides for a reduction in workers' compensation benefits for those receiving Social Security retirement…”
Frazier v. Dep't of Labor & Indus., 3 P.3d 221 (Wash. Ct. App. 2000). “He argues that because he received a lump sum disability payment rather than monthly benefits, he was not a person "receiving compensation" as RCW 51.32.225 uses that phrase and, thus, there was no statutory authorization for the deduction.”
Potter v. Dep't of Labor & Indus., 101 Wash. App. 399 (Wash. Ct. App. 2000). “About six weeks after RCW 51.32.225 became effective on July 1, 1986, the Department issued an order reducing the claimant’s disability payments by the amount of Social Security retirement benefits he had been receiving.”
Potter v. Dep't of Labor & Ind., 3 P.3d 229 (Wash. Ct. App. 2000). “About six weeks after RCW 51.32.225 became effective on July 1, 1986, the Department issued an order reducing the claimant's disability payments by the amount of social security retirement benefits he had been receiving.”
Frazier v. Dep't of Labor & Indus., 101 Wash. App. 411 (Wash. Ct. App. 2000). “He argues that because he received a lump sum disability payment rather than monthly benefits, he was not a person “receiving compensation” as RCW 51.32.225 uses that phrase and, thus, there was no statutory authorization for the deduction.”
— Wash. Rev. Code § 51.32.225(2) — 5 cases
Frazier v. Dep't of Labor & Indus., 3 P.3d 221 (Wash. Ct. App. 2000). “He argues that because he received a lump sum disability payment rather than monthly benefits, he was not a person "receiving compensation" as RCW 51.32.225 uses that phrase and, thus, there was no statutory authorization for the deduction.”
Frazier v. Dep't of Labor & Indus., 101 Wash. App. 411 (Wash. Ct. App. 2000). “He argues that because he received a lump sum disability payment rather than monthly benefits, he was not a person “receiving compensation” as RCW 51.32.225 uses that phrase and, thus, there was no statutory authorization for the deduction.”
Margaret West, V. State Of Wa, Dept Of L & I (Wash. Ct. App. 2023). “But once they began receiving social security retirement benefits after reaching retirement age, DLI reduced their disability benefits based on RCW 51.32.225. 42 U.S.C § 424a(a) provides that if a person has not yet reached retirement age and is entitled to receive both social…”
Owen M. Henderson v. Dep't Of Labor & Indus. (Wash. Ct. App. 2017).
Zbigniew Laskowski v. State Of Washington, Dep't Of Labor & Indus. (Wash. Ct. App. 2020).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.