Washington wage lien requirements became the focus of a significant published Court of Appeals decision involving security guards who sought to recover unpaid wages from their former employer.

In Radulescu v. West Coast Security, No. 87987-1-I, the Washington Court of Appeals, Division One, considered whether representatives of a certified employee class could record wage liens against apartment properties where other class members had worked.

The court answered that question yes. However, it also ruled that the particular liens were legally insufficient because they did not identify the employees who actually performed services at the properties.

The decision highlights an important distinction under Washington’s Wage Recovery Act: The authority to file a wage lien does not eliminate the obligation to comply with statutory notice requirements.

What Happened in the West Coast Security Wage Lawsuit?

Andrew Radulescu and Justin Green were hourly security officers employed by West Coast Security.

They brought a lawsuit alleging multiple employment violations, including unpaid wages, missed meal and rest periods, improper wage deductions, and violations of Seattle employment laws.

The claims also included allegations involving wages due at termination and willful failure to pay wages.

West Coast Security defaulted in the lawsuit. The superior court certified a class of current and former security guards and appointed Radulescu and Green as class representatives.

The Court Entered a $2.64 Million Default Judgment

After class certification, the plaintiffs obtained a default judgment totaling $2,642,144.36.

The judgment included compensation-related amounts and other damages and sanctions. The calculations relied partly on payroll records obtained from third-party vendors, along with estimates for periods when complete data was unavailable.

However, obtaining a judgment against the security company did not automatically result in payment.

The class representatives turned to Washington’s Wage Recovery Act to pursue additional collection options.

Washington Wage Lien Requirements Under the Wage Recovery Act

Washington’s Wage Recovery Act, chapter 60.90 RCW, provides qualifying employees with lien rights intended to help secure payment of certain wage claims.

Depending on the circumstances and statutory requirements, those rights can extend to particular property connected to the employee’s work.

The relevant statutes include:

• RCW 60.90.010, which defines important terms.
• RCW 60.90.020, which establishes wage lien rights.
• RCW 60.90.030, which establishes recording and notice requirements.
• RCW 60.90.070, which addresses enforcement and foreclosure.

Can Security Guards Claim Wage Liens Against Property They Protected?

The Wage Recovery Act includes a provision allowing qualifying employees to assert wage liens against real property they maintained.

Under RCW 60.90.010(11), the statutory definition of maintaining property includes activities such as protecting, managing, monitoring, cleaning, repairing, and improving real property.

That definition is broader than ordinary building maintenance.

Security work may therefore qualify when the statutory conditions are satisfied.

However, a lien against a particular property must be based on valid lien rights belonging to an employee whose qualifying work connects that employee to the property.

Why the Security Guards Filed Liens Against Apartment Buildings

The class representatives recorded wage liens against two apartment properties where class members had allegedly provided security services.

The recorded amounts were:

• Portsmith Apartments: $40,507.61.
• Sunrise Lane Apartments: $18,819.49.

Together, the liens claimed $59,327.10.

Neither Radulescu nor Green personally worked at either property.

Instead, they filed the liens as representatives of the certified class.

The notices identified the class representatives and provided contact information for class counsel. But they did not name the individual employees who had actually worked at Portsmith or Sunrise Lane.

The apartment property owners challenged the liens, arguing that the Wage Recovery Act did not permit the representatives to file them and that the notices failed to comply with the statute.

Can Class Representatives File Wage Liens for Other Employees?

The first major legal issue was whether class representatives could record wage liens on behalf of absent class members.

The property owners argued that the statute expressly permits class representatives to bring foreclosure actions but does not specifically identify them as people authorized to record liens.

The Court of Appeals rejected that argument.

The Court Recognized Class Representatives’ Authority

The appellate court examined the Wage Recovery Act as a whole.

RCW 60.90.070(6) expressly permits certain representatives, including class representatives, to pursue wage lien foreclosure.

Meanwhile, the model lien form in RCW 60.90.030(4) contemplates that an authorized representative may sign and record a lien on behalf of a claimant.

Reading those provisions together, the court concluded that class representatives may record wage liens on behalf of employees who possess valid lien rights.

The court reasoned that allowing class representatives to enforce liens through a class action, while requiring every employee to record a separate lien first, would be an unnecessarily strained interpretation of the statute.

This portion of the ruling is important for workers pursuing collective wage recovery.

Class representatives may act for employees, but they must still comply with the legal requirements applicable to the employees’ individual lien rights.

Why the Court Rejected the Wage Lien Notices

Although the representatives had authority to file liens, the notices themselves were defective.

Under RCW 60.90.030(1)(a)(i), a wage lien notice must provide identifying information for the lien claimant, including the claimant’s name, telephone number, and address.

The appellate court emphasized that a class representative and a wage claimant are not necessarily the same person.

The Actual Employees Were Not Identified

The recorded notices named Radulescu and Green and referred generally to other similarly situated employees.

But they did not identify which class members had performed qualifying work at the two apartment properties.

That omission was decisive.

The employees who actually maintained or protected the properties were the people holding the underlying substantive lien rights.

The class representatives could act on their behalf, but that representative authority did not transform the representatives into the employees who performed the work.

Nor did it eliminate the statutory requirement to identify the actual claimants.

The Court of Appeals held that the notices failed to comply, or substantially comply, with the applicable content requirements.

Why Does Identifying Each Worker Matter?

A wage lien can encumber real property owned by someone other than the employee’s direct employer.

That makes accurate notice especially important.

Property owners need enough information to evaluate whether a claimed lien has a valid factual and legal basis.

In this case, identifying the actual employees would help establish the connection between the claimed unpaid wages and the particular apartment property.

The court explained that representative litigation does not excuse the absence of that information.

Wage Lien Deadlines and Property Owner Challenges

The appellate court also discussed the Wage Recovery Act’s procedures for resolving lien disputes promptly.

Under RCW 60.90.090, wage liens are subject to statutory deadlines involving the underlying wage claim and foreclosure proceedings.

The opinion discusses an eight-month period measured from recording the lien for the specified actions necessary to preserve lien rights.

The court also referred to RCW 60.90.130, which provides procedures for challenging certain wage liens.

These requirements reflect the importance of timely, sufficiently detailed claims.

A property owner should not have to guess which workers allegedly performed qualifying services or whose unpaid wages support a recorded encumbrance.

For employees and their representatives, this means that careful documentation of work locations, dates, and claimant identities can be essential.

What Did the Washington Court of Appeals Decide?

The appellate court reached two central conclusions.

First, the Wage Recovery Act permits class representatives to record wage liens on behalf of employees with valid lien rights.

Second, the notices recorded against the apartment properties were insufficient because they failed to identify the actual workers who maintained those properties.

The Court of Appeals reversed the superior court’s denial of the property owners’ motion to dismiss.

It directed dismissal of the supplemental complaint and remanded for proceedings consistent with its opinion.

Did the Court Overturn the $2.64 Million Wage Judgment?

No.

The decision addressed the attempted wage lien enforcement against the apartment property owners.

It did not overturn the underlying default judgment entered against West Coast Security.

That distinction matters. A worker may possess an underlying wage claim or judgment while still encountering legal obstacles when attempting to enforce a particular lien.

The court’s ruling concerned the statutory sufficiency of the recorded notices, not a determination that the security guards had been properly paid.

What This Case Means for Washington Employees

Employees pursuing unpaid wages should understand that wage liens can provide an additional enforcement mechanism when the statutory requirements are met.

But obtaining a judgment or participating in a class action does not automatically establish a valid lien against every property where employees worked.

The connection between the individual employee, the qualifying services, the property, and the wage claim must be supported.

Why Employment Records Matter

For employees whose work takes place at multiple locations, records identifying where and when they worked may become especially important.

Security officers, cleaners, maintenance workers, and others who perform qualifying services at properties owned by third parties may need documentation connecting their unpaid wages to particular locations.

Employers and property owners also benefit from accurate records because they can help clarify which claims are supported.

What This Case Means for Property Owners

Property owners may face wage lien claims arising from services performed by employees of outside contractors.

The Radulescu decision confirms that property owners may challenge recorded notices that fail to identify the employees whose work allegedly created the lien rights.

However, the decision does not mean that wage liens asserted by class representatives are categorically invalid.

The court expressly recognized the representatives’ authority when the underlying employees possess valid lien rights and the statutory requirements are satisfied.

The Key Lesson From Radulescu v. West Coast Security

The central lesson is that Washington wage lien requirements apply even when employees pursue their claims through a certified class action.

The Wage Recovery Act permits representative enforcement, but it also requires sufficient information to identify the people whose rights are being enforced.

For employees, the decision underscores the importance of preparing accurate lien notices.

For property owners, it demonstrates why the identity of the actual wage claimants matters when evaluating a recorded lien.

And for anyone involved in wage litigation, the case illustrates the difference between obtaining a wage judgment and successfully enforcing that judgment against particular property.

Contact Blanford Law

Disputes involving unpaid wages, recorded liens, and the enforcement of judgments can involve complicated statutory requirements and deadlines.

Understanding the applicable law and the available remedies is important before pursuing or challenging a claim.

Contact Blanford Law today at ken@blanfordlaw.com or 253-720-9304 for guidance on your legal matter.

Additional Resources

Related Blanford Law Article

Washington HOA Fee Disputes: Court Orders Money Judgment

Discusses Hillius v. 18 Paradise LLP, a Washington Court of Appeals decision explaining how courts can enforce established legal rights through monetary judgments, even when a separate Consumer Protection Act claim fails.

Washington State Statutes

RCW 60.90.020 — Wage Liens Authorized

Explains when qualifying employees may claim wage liens against certain property, including real property they maintained, protected, or monitored.

RCW 60.90.030 — Wage Lien Recording Requirements

Establishes the procedures and required information for recording wage liens, including identifying the actual wage claimants—an issue central to Radulescu v. West Coast Security.

This article provides general information about Washington law and is not legal advice. Legal rights and deadlines depend on the facts and applicable law.