The default judgment was the easy part - collecting it took a different strategy
Security guards who were never paid turned a $2.6 million default judgment into a lesson about paperwork.
Washington’s Court of Appeals ruled on October 12 that class representatives can record wage liens on behalf of fellow workers - but only if they name the actual people who did the work.
The case traces back to West Coast Security, a Nevada-based firm that employed hourly guards across Washington. Two former officers filed a class action alleging the company failed to provide rest and meal breaks, underpaid wages, withheld final paychecks, made unlawful deductions, and refused to reimburse expenses. One also alleged wrongful discharge and retaliation.
West Coast Security never responded.
The court certified a class of all hourly guards employed from August 2018 onward who were based in Washington, then entered a default judgment of $2,642,144.36 covering unpaid wages, liquidated and exemplary damages, sanctions, and one guard’s personal claims.
Winning the judgment was the easy part. Collecting it was another matter.
The class representatives turned to Washington’s Wage Recovery Act, which lets unpaid workers place liens on properties they maintained. They recorded liens on two apartment complexes - Portsmith Apartments and Sunrise Lane Apartments - that class members had patrolled. The liens totalled $40,507.61 and $18,819.49 respectively.
The catch: neither class representative had personally worked at those properties. The liens listed only their names and class counsel’s contact details, not the individual guards who had actually walked those sites.
The appeals court split its ruling. On the threshold question - can class representatives record liens at all on behalf of absent members? - the answer was yes. The WRA already allows class representatives to bring foreclosure actions, and requiring every guard to file their own lien individually before a class action could proceed made no logical sense.
But these particular liens failed. The statute requires a recorded lien to identify the worker who maintained the property - name, phone number, and address. A class representative who steps into a worker’s shoes still has to fill in the same blanks. Listing only the representatives and their lawyers was not enough.
The court reversed the lower court and dismissed the supplemental complaint against the property owners, remanding for further proceedings. The underlying $2.6 million judgment against West Coast Security was not disturbed.
For HR teams and employers engaging contracted security or maintenance staff, the takeaway is direct: wage violations do not stay contained. Washington law gives unpaid workers a route to the property itself - provided the right names are on the form.
