Revised Code of Washington

Wash. Rev. Code § 72.09.111 (2026)

✓ current as of May 2026

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(1) The secretary shall deduct taxes and legal financial obligations from the wages, gratuities, or workers' compensation benefits payable directly to the inmate under chapter 51.32 RCW, of each inmate working in correctional industries work programs, or otherwise receiving such wages, gratuities, or benefits. The secretary shall also deduct child support payments from the gratuities of each inmate working in class II through class IV correctional industries work programs. The secretary shall develop a formula for the distribution of offender wages, gratuities, and benefits. The formula shall not reduce the inmate account below the indigency level, as defined in RCW 72.09.015.

(a) The formula shall include the following maximum allowable deductions from class I wages and from all others earning at least minimum wage:

(i) Five percent to the crime victims' compensation account provided in RCW 7.68.045;

(ii) Ten percent to a department personal inmate savings account;

(iii) Twenty percent to the department to contribute to the cost of incarceration;

(iv) Twenty percent for payment of legal financial obligations for all inmates who have legal financial obligations owing in any Washington state superior court; and

(v) Twenty percent for payment of any civil judgment for assault for inmates who are subject to a civil judgment for assault in any Washington state court or federal court.

(b) The formula shall include the following minimum deductions from class II gross gratuities:

(i) Five percent to the crime victims' compensation account provided in RCW 7.68.045;

(ii) Ten percent to a department personal inmate savings account;

(iii) Fifteen percent to the department to contribute to the cost of incarceration;

(iv) Twenty percent for payment of legal financial obligations for all inmates who have legal financial obligations owing in any Washington state superior court;

(v) Fifteen percent for any child support owed under a support order; and

(vi) Fifteen percent for payment of any civil judgment for assault for inmates who are subject to a civil judgment for assault in any Washington state court or federal court.

(c) The formula shall include the following minimum deductions from any workers' compensation benefits paid pursuant to RCW 51.32.080:

(i) Five percent to the crime victims' compensation account provided in RCW 7.68.045;

(ii) Ten percent to a department personal inmate savings account;

(iii) Twenty percent to the department to contribute to the cost of incarceration; and

(iv) An amount equal to any legal financial obligations owed by the inmate established by an order of any Washington state superior court up to the total amount of the award.

(d) The formula shall include the following minimum deductions from class III gratuities:

(i) Five percent for the crime victims' compensation account provided in RCW 7.68.045;

(ii) Fifteen percent for any child support owed under a support order; and

(iii) Fifteen percent for payment of any civil judgment for assault for inmates who are subject to a civil judgment for assault in any Washington state court or federal court.

(e) The formula shall include the following minimum deduction from class IV gross gratuities:

(i) Five percent to the department to contribute to the cost of incarceration;

(ii) Fifteen percent for any child support owed under a support order; and

(iii) Fifteen percent for payment of any civil judgment for assault for inmates who are subject to a civil judgment for assault in any Washington state court or federal court.

(2) Any person sentenced to life imprisonment without possibility of release or parole under *chapter 10.95 RCW or sentenced to death shall be exempt from the requirement under subsection (1)(a)(ii), (b)(ii), or (c)(ii).

(3)(a) The department personal inmate savings account, together with any accrued interest, may be made available to an inmate at the following times:

(i) During confinement to pay for accredited postsecondary educational expenses;

(ii) Prior to the release from confinement to pay for department-approved reentry activities that promote successful community reintegration; or

(iii) When the secretary determines that an emergency exists for the inmate.

(b) The secretary shall establish guidelines for the release of funds pursuant to (a) of this subsection, giving consideration to the inmate's need for resources at the time of his or her release from confinement.

(c) Any funds remaining in an offender's personal inmate savings account shall be made available to the offender at the time of his or her release from confinement.

(4) The management of classes I, II, and IV correctional industries may establish an incentive payment for offender workers based on productivity criteria. This incentive shall be paid separately from the hourly wage/gratuity rate and shall not be subject to the specified deduction for cost of incarceration.

(5) In the event that the offender worker's wages, gratuity, or workers' compensation benefit is subject to garnishment for support enforcement, the crime victims' compensation account, savings, and cost of incarceration deductions shall be calculated on the net wages after taxes, legal financial obligations, and garnishment.

(6) The department shall explore other methods of recovering a portion of the cost of the inmate's incarceration and for encouraging participation in work programs, including development of incentive programs that offer inmates benefits and amenities paid for only from wages earned while working in a correctional industries work program.

(7) The department shall develop the necessary administrative structure to recover inmates' wages and keep records of the amount inmates pay for the costs of incarceration and amenities. All funds deducted from inmate wages under subsection (1) of this section for the purpose of contributions to the cost of incarceration shall be deposited in a dedicated fund with the department and shall be used only for the purpose of enhancing and maintaining correctional industries work programs.

(8) It shall be in the discretion of the secretary to apportion the inmates between class I and class II depending on available contracts and resources.

(9) Nothing in this section shall limit the authority of the department of social and health services division of child support from taking collection action against an inmate's moneys, assets, or property pursuant to chapter 26.23, 74.20, or 74.20A RCW.

(10) For purposes of this section, "wages" means monetary compensation due to an offender worker by reason of his or her participation in a class I work program, subject to allowable deductions.

[ 2017 c 81 s 1; 2011 c 282 s 2. Prior: 2010 c 122 s 5; 2010 c 116 s 1; 2009 c 479 s 60; 2007 c 483 s 605; 2004 c 167 s 7; prior: 2003 c 379 s 25; 2003 c 271 s 2; 2002 c 126 s 2; 1999 c 325 s 2; 1994 sp.s. c 7 s 534; 1993 sp.s. c 20 s 2.]

Notes:

*Reviser's note: RCW 10.95.040 through 10.95.901 relating to "death sentence" was repealed by 2023 c 102 s 21.

Effective date—2010 c 116: "This act takes effect July 1, 2010." [ 2010 c 116 s 2.]

Effective date—2009 c 479: See note following RCW 2.56.030.

Finding—Intent—2007 c 483: See note following RCW 35.82.340.

Findings—2007 c 483: See RCW 72.78.005.

Severability—Effective dates—2003 c 379: See notes following RCW 9.94A.728.

Intent—Purpose—2003 c 379 ss 13-27: See note following RCW 9.94A.760.

Effective date—1994 sp.s. c 7 s 534: "Section 534 of this act shall take effect June 30, 1994." [ 1994 sp.s. c 7 s 536.]

Finding—Intent—Severability—1994 sp.s. c 7: See notes following RCW 43.70.540.

Effective date—1993 sp.s. c 20 s 2: "Section 2 of this act shall take effect June 30, 1994." [ 1993 sp.s. c 20 s 10.]

Notes of Decisions

Cited in 32 cases (1 in the last 5 years), 1998–2025 · leading case: Dean v. Lehman, 18 P.3d 523 (Wash. 2001).

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Dean v. Lehman, 18 P.3d 523 (Wash. 2001). · cites it 17× “Although RCW 72.09.111 previously required the 20 percent deduction to be deposited in the general fund, this provision was amended to provide that these funds be used “only for the purpose of enhancing and maintaining correctional industries work programs.”

In Re Pierce, 268 P.3d 907 (Wash. 2011). · cites it 32× “RCW 72.09.111 ¶ 15 RCW 72.09.111 outlines various formulas the Department must use in deducting from inmate wages earned in the institutional work program.”

In re the Pers. Restraint of Pierce, 173 Wash. 2d 372 (Wash. 2011). · cites it 29× “RCW 72.09.111 ¶15 RCW 72.09.111 outlines various formulas the Department must use in deducting from inmate wages earned in the institutional work program.”

Anderson v. State, Dept. of Corr., 154 P.3d 220 (Wash. 2007). · cites it 21× “020's mandate that all LFOs be paid, Anderson and Nordlund point to the fact that LFO payments will be made by some LWOP inmates from their work related income pursuant to RCW 72.09.111. But RCW 72.09.111 does not limit the Department's authority to satisfy LFOs only from work…”

Anderson v. Dep't of Corr., 159 Wash. 2d 849 (Wash. 2007). · cites it 14× “020’s mandate that all LFOs be paid, Anderson and Nordlund point to the fact that LFO payments will be made by some LWOP inmates from their work-related income pursuant to RCW 72.09.111. But RCW 72.09.111 does not limit the Department’s authority to satisfy LFOs only from…”

Thomas v. Lehman, 138 Wash. App. 618 (Wash. Ct. App. 2007). · cites it 12× “” 1 RCW 72.09.111 directs the DOC to maintain PISAs and to distribute funds to inmates upon their release or for “emergencies,” as determined by the DOC secretary.”

Paul A. Wright, on Behalf of All Similarly Situated Persons v. Chase Riveland, 219 F.3d 905 (9th Cir. 2000). · cites it 6× “Likewise, we conclude that the victims’ compensation deduction under RCW 72.09.111(1)(a)(i) serves the traditional goals of deterrence and is therefore punishment.”

In Re the Pers. Restraint of Metcalf, 963 P.2d 911 (Wash. Ct. App. 1998). · cites it 7× “One statute requires deductions from a prisoner’s wages (RCW 72.09.111, effective June 30, 1994);* 1 the other *171 requires deductions from all other funds received (RCW 72.”

Mitchell v. Washington State Inst. of Pub. Policy, 225 P.3d 280 (Wash. Ct. App. 2009). · cites it 2× “” Former RCW 72.09.111(1) (2007). Similarly, prisoners “employed under a work release plan shall surrender to the secretary .”

State Treasurer v. Abbott, 660 N.W.2d 714 (Mich. 2003). · cites it 2× “receives any funds in addition to his or her wages or gratuities, the additional funds shall be subject to the deductions in RCW 72.”

Thomas v. Lehman, 158 P.3d 86 (Wash. Ct. App. 2007). · cites it 13× “" [1] RCW 72.09.111 directs the DOC to maintain PISAs and to distribute funds to inmates upon their release or for "emergencies," as determined by the DOC secretary.”

State v. Crook, 146 Wash. App. 24 (Wash. Ct. App. 2008). · cites it 2× “020; RCW 72.09.111(1); Mahone, 98 Wn. App. at 348 ; Blank, 131 Wn.”

Show all 32 citing cases →

— Wash. Rev. Code § 72.09.111(1) — 15 cases

Anderson v. State, Dept. of Corr., 154 P.3d 220 (Wash. 2007). “020's mandate that all LFOs be paid, Anderson and Nordlund point to the fact that LFO payments will be made by some LWOP inmates from their work related income pursuant to RCW 72.09.111. But RCW 72.09.111 does not limit the Department's authority to satisfy LFOs only from work…”

Anderson v. Dep't of Corr., 159 Wash. 2d 849 (Wash. 2007). “020’s mandate that all LFOs be paid, Anderson and Nordlund point to the fact that LFO payments will be made by some LWOP inmates from their work-related income pursuant to RCW 72.09.111. But RCW 72.09.111 does not limit the Department’s authority to satisfy LFOs only from…”

Mitchell v. Washington State Inst. of Pub. Policy, 225 P.3d 280 (Wash. Ct. App. 2009). “” Former RCW 72.09.111(1) (2007). Similarly, prisoners “employed under a work release plan shall surrender to the secretary .”

State v. Crook, 146 Wash. App. 24 (Wash. Ct. App. 2008). “020; RCW 72.09.111(1); Mahone, 98 Wn. App. at 348 ; Blank, 131 Wn.”

Thomas v. Lehman, 138 Wash. App. 618 (Wash. Ct. App. 2007). “” 1 RCW 72.09.111 directs the DOC to maintain PISAs and to distribute funds to inmates upon their release or for “emergencies,” as determined by the DOC secretary.”

— Wash. Rev. Code § 72.09.111(1)(a) — 5 cases

Dean v. Lehman, 18 P.3d 523 (Wash. 2001). “Although RCW 72.09.111 previously required the 20 percent deduction to be deposited in the general fund, this provision was amended to provide that these funds be used “only for the purpose of enhancing and maintaining correctional industries work programs.”

In Re Pierce, 268 P.3d 907 (Wash. 2011). “RCW 72.09.111 ¶ 15 RCW 72.09.111 outlines various formulas the Department must use in deducting from inmate wages earned in the institutional work program.”

Dean v. Lehman, 18 P.3d 523 (Wash. 2001).

Willoughby v. Dept. of Labor & Indus., 57 P.3d 611 (Wash. 2002).

— Wash. Rev. Code § 72.09.111(1)(a)(i) — 1 case

Paul A. Wright, on Behalf of All Similarly Situated Persons v. Chase Riveland, 219 F.3d 905 (9th Cir. 2000). “Likewise, we conclude that the victims’ compensation deduction under RCW 72.09.111(1)(a)(i) serves the traditional goals of deterrence and is therefore punishment.”

— Wash. Rev. Code § 72.09.111(1)(a)(ii) — 1 case

In Re Smith, 125 P.3d 233 (Wash. Ct. App. 2005).

— Wash. Rev. Code § 72.09.111(1)(a)(iii) — 2 cases

State of Washington v. Joel Matthew Groves (Wash. Ct. App. 2019).

— Wash. Rev. Code § 72.09.111(1)(a)(iv) — 2 cases

State of Washington v. Patrick Gale Wilson (Wash. Ct. App. 2013).

— Wash. Rev. Code § 72.09.111(1)(b) — 1 case

— Wash. Rev. Code § 72.09.111(1)(d) — 4 cases

Dean v. Lehman, 18 P.3d 523 (Wash. 2001).

In re the Pers. Restraint of Smith, 130 Wash. App. 897 (Wash. Ct. App. 2005).

— Wash. Rev. Code § 72.09.111(2) — 4 cases

In re the Pers. Restraint of Smith, 130 Wash. App. 897 (Wash. Ct. App. 2005).

In Re Smith, 125 P.3d 233 (Wash. Ct. App. 2005).

— Wash. Rev. Code § 72.09.111(3) — 6 cases

Thomas v. Lehman, 158 P.3d 86 (Wash. Ct. App. 2007). “" [1] RCW 72.09.111 directs the DOC to maintain PISAs and to distribute funds to inmates upon their release or for "emergencies," as determined by the DOC secretary.”

In re the Pers. Restraint of Smith, 130 Wash. App. 897 (Wash. Ct. App. 2005).

Dean v. Lehman, 18 P.3d 523 (Wash. 2001).

— Wash. Rev. Code § 72.09.111(7) — 2 cases

In re the Pers. Restraint of Pierce, 173 Wash. 2d 372 (Wash. 2011). “RCW 72.09.111 ¶15 RCW 72.09.111 outlines various formulas the Department must use in deducting from inmate wages earned in the institutional work program.”

— Wash. Rev. Code § 72.09.111(d) — 1 case

In Re Smith, 125 P.3d 233 (Wash. Ct. App. 2005).

— Wash. Rev. Code § 72.09.111(l)(a) — 4 cases

In Re the Pers. Restraint of Metcalf, 963 P.2d 911 (Wash. Ct. App. 1998). “One statute requires deductions from a prisoner’s wages (RCW 72.09.111, effective June 30, 1994);* 1 the other *171 requires deductions from all other funds received (RCW 72.”

State Treasurer v. Abbott, 660 N.W.2d 714 (Mich. 2003). “receives any funds in addition to his or her wages or gratuities, the additional funds shall be subject to the deductions in RCW 72.”

— Wash. Rev. Code § 72.09.111(l)(a)(i) — 1 case

— Wash. Rev. Code § 72.09.111(l)(a)(iii) — 1 case

— Wash. Rev. Code § 72.09.111(l)(a)(iv) — 1 case

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