Sampson v. Knight Transp., Inc., 448 P.3d 9

Plaintiffs Valerie Sampson and David Raymond are Washington commercial truck drivers who sued Knight Transportation on behalf of a putative class, alleging piece-rate pay failed to separately compensate for non‑piece tasks (loading, fueling, inspections, detention, washing, etc.).
Knight pays long‑haul drivers a per‑mile mileage rate (varying by trip length) and short‑haul drivers a flat load rate; both rates were intended to cover routine nondriving tasks and include extra pay for certain additional duties or long waits.
The federal district court treated the pay schemes as piecework and certified the question whether the Washington Minimum Wage Act (MWA) requires nonagricultural piece‑rate employees to be paid hourly for time spent on non‑piece tasks.
The Washington Department of Labor & Industries regulation WAC 296‑126‑021 permits employers to determine MWA compliance by dividing total weekly wages by total hours worked (workweek averaging).
The Washington Supreme Court held that WAC 296‑126‑021 validly implements the MWA for nonagricultural piece‑rate employees and that the MWA does not require separate per‑hour pay for non‑piece activities so long as workweek averaging yields at least the minimum wage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the MWA require nonagricultural piece‑rate employees to be paid per hour for time spent on non‑piece tasks?	Sampson: Yes — MWA guarantees a per‑hour right; non‑piece time must be paid separately at ≥ minimum wage.	Knight: No — WAC 296‑126‑021 authorizes workweek averaging of all wages and hours; piece pay may cover non‑piece tasks.	No. The court held the MWA does not require separate hourly pay where workweek averaging under WAC 296‑126‑021 yields at least minimum wage.
Is WAC 296‑126‑021 inconsistent with the MWA or invalid?	Sampson: Carranza requires per‑hour compensation and renders WAC 296‑126‑021 invalid insofar as it allows averaging.	Knight/Dept.: The regulation reasonably implements MWA and is presumed valid; it fills a statutory gap for nonagricultural piecework.	WAC 296‑126‑021 is a valid implementation of the MWA for nonagricultural workers and does not conflict with the statute.
Does the court's decision in Carranza control and require per‑hour pay for all pieceworkers?	Sampson: Carranza's plain‑language reading of the MWA applies to all employers, not just agriculture.	Knight: Carranza was limited to agricultural pieceworkers who are expressly excluded from WAC 296‑126‑021.	Carranza is limited to agricultural workers; it does not invalidate WAC 296‑126‑021 for nonagricultural workers.

Carranza v. Dovex Fruit Co., 190 Wn.2d 612 (2018) (held agricultural pieceworkers are entitled to separate hourly pay for non‑piece tasks)
Lopez Demetrio v. Sakuma Bros. Farms, 183 Wn.2d 649 (2015) (addressed pay rules for agricultural piece‑rate workers and rest breaks)
Hill v. Xerox Bus. Servs., LLC, 191 Wn.2d 751 (2018) (clarified limits on what qualifies as a piecework plan)
Wash. Pub. Ports Ass'n v. Dep't of Revenue, 148 Wn.2d 637 (2003) (deference to administrative regulations when reasonably consistent with statute)
Erickson v. Dep't of Labor & Indus., 185 Wash. 618 (1936) (historical authority on piecework compensation concepts)