Willoughby v. Department of Labor & Industries

Summary

The Washington Supreme Court held that statutory provisions suspending permanent partial disability benefits for incarcerated workers without statutory beneficiaries violated due process and equal protection as applied to the plaintiffs. The court also held that the provisions did not conflict with Washington’s statutory prohibition against forfeiture of prisoners’ property. The superior court’s judgment was affirmed, and the cases were remanded.

Holdings

1. RCW 51.32.040(3)(a) and RCW 72.60.102 do not conflict with RCW 9.92.110 because they suspend payment during confinement, rather than impose a forfeiture by reason of the worker's conviction.
2. Applying RCW 51.32.040(3)(a) and RCW 72.60.102 to Willoughby and Cain deprives them of property without due process of law.
3. RCW 51.32.040(3)(a), as applied to prisoners through RCW 72.60.102, violates equal protection.

Questions Presented

1. Whether RCW 51.32.040(3)(a) and RCW 72.60.102 conflict with RCW 9.92.110's prohibition against forfeiture of a prisoner's property by reason of conviction.
2. Whether withholding permanent partial disability benefits from incarcerated workers without statutory beneficiaries violates due process.
3. Whether the statutory classification distinguishing incarcerated workers based on the existence of beneficiaries or the likelihood of release violates equal protection.

Disposition

affirmed