An appellate court in Washington state recently held a hospital liable for paying employees who worked through meal periods for their time worked, plus compensation for an additional break as a penalty, highlighting Washington employers’ obligations to ensure employees take breaks from work during their meal and rest periods.

On Sept. 30, a panel for the Court of Appeals for the State of Washington affirmed a lower-court summary judgment ruling that sided with employees, finding that they were owed additional compensation in the amount of thirty minutes of pay for each missed meal period to compensate them for the deprivation of their right to take a break from work during the meal periods, plus prejudgment interest.

In Androckitis v. Virginia Mason Medical Center, the appellate court rejected the hospital’s argument that the employees need only be compensated for the time of their meal periods and that additional pay for the missed periods was an improper, judicially created penalty.

But the court stated that it is well-established law that the Washington Industrial Welfare Act (IWA) provides employees “a right to the respite of a meal and rest period, an implied cause of action to enforce that right, and a remedy to compensate them for the loss of the statutorily granted opportunity to have respite from work.”

The decision is significant for employers because it underscores that Washington courts will take employers’ statutory obligations to provide meal and rest...

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