Wash. State Nurses Ass'n v. Cmty. Health Sys., Inc., 195 Wn. 2d 825

Summary

The Washington Supreme Court held that the Washington State Nurses Association lacked associational standing to seek wage-and-hour damages on behalf of its members because the damages depended on representative testimony and were not certain, easily ascertainable, or within the defendant’s knowledge. The court declined to create an exception permitting representative testimony to establish damages in associational standing cases and reversed the trial court’s judgment.

Holdings

1. An association may bring a damages claim on behalf of its members under the third prong of the associational-standing test only when the damages are certain, easily ascertainable, and within the knowledge of the defendant. Because the damages here required representative testimony and trial-court determinations concerning the rates of unpaid work and missed meal periods, WSNA lacked associational standing.

Questions Presented

1. Whether WSNA had associational standing to seek damages for its nurse members when proving the amount and extent of damages required representative testimony and fact-finding.
2. Whether representative testimony may establish uncertain or disputed damages in an associational wage-and-hour action without the procedural protections of a class or collective action.

Disposition

reversed