In LaCoursiere v. Camwest Development, Inc., No. 88298-3, the Washington Supreme Court construed the Washington wage rebate act, chapter 49.52 RCW (“WRA”). CamWest paid the plaintiff, a former manager, several bonuses during his employment. Pursuant to his employment agreement, a portion of plaintiff’s bonus was directly invested in a related LLC that was established to loan money to CamWest for real estate investment and development. When CamWest terminated plaintiff’s employment before his capital investment fully vested, he lost a portion of his investment in the LLC. The Washington Supreme Court affirmed the dismissal of plaintiff’s claim, finding that even though the bonuses constituted “wages,” there was no rebate of those wages that violated the WRA because plaintiff’s unvested interest reverted to the LLC and not to CamWest.
