A Washington appeals court has ruled that representatives in a class-action wage case can record property liens on behalf of other unpaid workers. However, the liens must identify the individual employees who performed the work at the properties.
The decision, issued on October 12, 2026, concerns a dispute involving West Coast Security, a Nevada-based company that employed hourly security guards across Washington. The case highlights how wage claims can extend beyond an employer when workers seek to recover unpaid earnings through property liens.
Two former security officers brought a class action alleging that the company failed to provide required rest and meal breaks, underpaid wages, withheld final paychecks, made unlawful deductions and failed to reimburse work-related expenses. One employee also alleged wrongful discharge and retaliation.
West Coast Security did not respond to the lawsuit. The court subsequently certified a class covering hourly guards employed by the company in Washington from August 2018 onward and entered a default judgment of $2,642,144.36. The amount included unpaid wages, liquidated and exemplary damages, sanctions and individual claims brought by one of the guards.
Wage liens created another route to recovery
Although the workers secured the judgment, collecting the money presented a separate challenge.
The class representatives relied on Washington's Wage Recovery Act, which allows workers with unpaid wage claims to place liens on properties they have maintained. They recorded liens against two apartment complexes where members of the class had provided security services: Portsmith Apartments and Sunrise Lane Apartments.
The liens amounted to $40,507.61 and $18,819.49, respectively.
However, neither class representative had personally worked at either property. The recorded documents included the representatives' names and their lawyers' contact details but did not identify the individual guards who had actually performed the work.
The property owners challenged the liens, arguing that the statutory identification requirements had not been met.
Court distinguishes between class representation and worker identification
The Washington Court of Appeals addressed whether class representatives could record wage liens on behalf of other workers.
It ruled that they could. The court reasoned that Washington's law already allows class representatives to bring foreclosure actions on behalf of workers. Requiring every employee to record an individual lien before a class action could proceed would undermine that process.
However, the court also found that the specific liens in this case were deficient.
Under the Wage Recovery Act, a recorded lien must identify the worker who maintained the property, including the worker's name, telephone number and address. Representing other employees does not remove this requirement.
Because the two liens identified only the class representatives and their legal counsel, rather than the guards who had worked at the properties, they did not meet the statutory requirements.
The appeals court reversed the lower court's decision and dismissed the supplemental complaint against the property owners, remanding the matter for further proceedings. The underlying $2.64 million default judgment against West Coast Security was not overturned.
What HR teams and employers should consider
The ruling is relevant to organisations that outsource security, maintenance and other site-based services. Employers and property operators should pay close attention to wage compliance throughout their contractor relationships, rather than assuming that employment-related liabilities remain confined to the service provider.
HR, procurement and legal teams should also ensure that contractor arrangements include clear responsibilities for wage payments, working hours, statutory breaks and expense reimbursements. Accurate records of which workers are assigned to specific sites can also become important when wage disputes arise.
The case demonstrates that unpaid wage claims can create recovery efforts involving properties where contracted employees performed their work. It also shows why accurate worker identification and documentation matter when employers, contractors and property owners face wage-related disputes.
