Summary
The Washington Supreme Court held that RCW 49.46.130(2)(g)(ii) unambiguously exempts individuals engaged in specified activities involving agricultural commodities from the Washington Minimum Wage Act's overtime requirement. The court concluded that the truck drivers were exempt even though they were employed by a trucking company rather than directly by farmers, and that the Court of Appeals improperly deferred to the Department of Labor and Industries' interpretation. The court reversed the partial summary judgment for unpaid overtime wages and remanded for further proceedings.
Holdings
- RCW 49.46.130(2)(g)(ii) is unambiguous, and its plain language exempts the truckers from Washington's overtime-wage requirement because they delivered agricultural commodities to storage, market, or a carrier for transportation to market.
- It was improper for the Court of Appeals to defer to the Department of Labor and Industries' informal interpretation or employ other statutory-construction tools before determining that the statute was ambiguous.
Questions Presented
- Whether RCW 49.46.130(2)(g)(ii) unambiguously exempts individuals who deliver agricultural commodities to storage, market, or a carrier for transportation to market from Washington's overtime-wage requirement.
- Whether the Court of Appeals improperly deferred to the Department of Labor and Industries' informal interpretation of RCW 49.46.130(2)(g)(ii) without first determining that the statute was ambiguous.
Disposition
reversed_and_remanded
Cases Cited (15)
- Agrilink Foods, Inc. v. Dep't of Revenue, 153 Wash. 2d 392, 396, 103 P.3d 1226 (2005)(followed)
- Drinkwitz v. Alliant Techsystems, Inc., 140 Wash. 2d 291, 295, 301, 996 P.2d 582 (2000)(followed)
- Marquis v. City of Spokane, 130 Wash. 2d 97, 104-05, 922 P.2d 43 (1996)(followed)
- Kilian v. Atkinson, 147 Wash. 2d 16, 20-21, 27, 50 P.3d 638 (2002)(followed)
- State v. Keller, 143 Wash. 2d 267, 276, 19 P.3d 1030 (2001)(followed)
- State v. Hahn, 83 Wash. App. 825, 831, 924 P.2d 392 (1996)(followed)
- Wash. State Coalition for the Homeless v. Dep't of Soc. & Health Servs., 133 Wash. 2d 894, 904, 949 P.2d 1291 (1997)(followed)
- Associated Gen. Contractors v. King County, 124 Wash. 2d 855, 865, 881 P.2d 996 (1994)(followed)
- Stahl v. Delicor of Puget Sound, Inc., 148 Wash. 2d 876, 879, 884-85, 64 P.3d 10 (2003)(followed)
- Concerned Ratepayers Ass'n v. Pub. Util. Dist. No. 1, 138 Wash. 2d 950, 959-60, 983 P.2d 635 (1999)(followed)
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Court Document
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