Ordinary Agency Principles Apply to RCW 49.52; Factual Issues Remain on Piercing Corporate Veil

In this unpaid wages case, complicated questions arose ?whether ?one ?of? the ?defendants ?was ?an ?agent?? ?of?? the? ?employees?? ?employer? ?for? ?the purpose of liability for wrongfully withheld wages. Both parties moved for summary judgment but the district court denied both motions.? ?The district court? certified ?four? legal? questions? for discretionary review by the court of appeals. ?The court refused to answer the legal questions but affirmed the denial of both motions for summary judgment. ?The employees? actual employer was an LLC.?? One of the two members of that LLC was also an LLC.? ?The court had little difficulty concluding that both LLCs were liable under RCW 49.52. ?But the court held that in order to hold an individual manager of the LLC which was in turn a ?manager?? of? the? employees?? employer individually liable under RCW 49.52, the employees had met the test for piercing the corporate ?veil.???? The ?court ?ruled ?that ?ordinary agency principles applied but that factual issues remained as to whether the corporate veil could be pierced. ?Dickend v. Alliance Analytical Labs., No. 23038-4-III (05/20/05; Brown, Schultheis, Allen).