Dobson v. Archibald

CourtWashington Supreme Court
DecidedFebruary 9, 2023
Docket100,862-7
StatusPublished

This text of Dobson v. Archibald (Dobson v. Archibald) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dobson v. Archibald, (Wash. 2023).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

The opinion that begins on the next page is a slip opinion. Slip opinions are the written opinions that are originally filed by the court. A slip opinion is not necessarily the court’s final written decision. Slip opinions can be changed by subsequent court orders. For example, a court may issue an order making substantive changes to a slip opinion or publishing for precedential purposes a previously “unpublished” opinion. Additionally, nonsubstantive edits (for style, grammar, citation, format, punctuation, etc.) are made before the opinions that have precedential value are published in the official reports of court decisions: the Washington Reports 2d and the Washington Appellate Reports. An opinion in the official reports replaces the slip opinion as the official opinion of the court. The slip opinion that begins on the next page is for a published opinion, and it has since been revised for publication in the printed official reports. The official text of the court’s opinion is found in the advance sheets and the bound volumes of the official reports. Also, an electronic version (intended to mirror the language found in the official reports) of the revised opinion can be found, free of charge, at this website: https://www.lexisnexis.com/clients/wareports. For more information about precedential (published) opinions, nonprecedential (unpublished) opinions, slip opinions, and the official reports, see https://www.courts.wa.gov/opinions and the information that is linked there. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON FEBRUARY 9, 2023 IN CLERK’S OFFICE SUPREME COURT, STATE OF WASHINGTON FEBRUARY 9, 2023 ERIN L. LENNON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

GINA DOBSON, ) No. 100862-7 ) Petitioner, ) ) v. ) EN BANC ) TREFAN ARCHIBALD, ) ) Filed: February 9, 2023 Respondent. ) ______________________________ )

MONTOYA-LEWIS, J.— In order to protect the public, the Washington State

Legislature passed a law requiring contractors to register with the Department of

Labor and Industries before advertising, offering to do work, or performing any work

as a contractor. RCW 18.27.020. In so doing, the legislature has stated an interest

in protecting the public from unreliable, fraudulent, financially irresponsible, or

incompetent contractors. RCW 18.27.140. Consequently, in any action where an

individual doing work as a contractor sues for breach of contract for work done as a

contractor, that individual is required to allege and prove that at the time they

performed the work, they were a registered contractor. RCW 18.27.080. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. Dobson v. Archibald No. 100862-7

In this case, a homeowner, Trefan Archibald, hired an individual, Gina

Dobson, to refinish his hardwood floors. Dobson worked as a longshoreman full-

time but did some construction work on the side. Archibald selected her for the job

based on a referral and her reputation of completing similar construction projects.

Upon completion of the floors, Archibald was dissatisfied with the results and

refused to pay the agreed-upon price. Dobson sued for breach of contract and, as

part of the suit, claimed she was not a contractor and did not need to be registered.

We are asked to determine two issues. First, whether such an individual is a

“contractor” under RCW 18.27.010(1)(a). Second, whether nonregistration under

RCW 18.27.080 is an affirmative defense that must be timely pleaded or is otherwise

waived.

The Court of Appeals held that Dobson was a contractor within the meaning

of the contractor registration statutes and that Archibald was not required to raise

nonregistration as an affirmative defense. We agree. We hold that Dobson is a

contractor as defined by statute and that registration is a prerequisite to suit.

Therefore, Dobson was precluded from bringing this lawsuit, and her breach of

contract action was properly dismissed. We affirm.

I. FACTS AND PROCEDURAL HISTORY

A. Factual Background

Dobson works as a longshoreman, loading and unloading ships at the Port of

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. Dobson v. Archibald No. 100862-7

Seattle’s seaport terminals. Over the last few years, Dobson has simultaneously

completed home repair work for pay on several occasions. Dobson never registered

as a contractor with the Department of Labor and Industries.

In 2018, Archibald, a homeowner in the Seattle area, contacted Dobson to

inquire about refinishing hardwood floors in his home. Archibald learned about

Dobson through a mutual friend; they never had any prior interactions. In 2016,

Dobson had done some work for this friend, such as remodeling his guest bathroom

and miscellaneous in-home repairs and construction work.

Dobson has acquired customers for her home repair work through a referral

process. For instance, Archibald’s friend was referred to Dobson by a second friend

for whom Dobson had also refinished hardwood floors and done some other

construction work. This second friend was referred to Dobson by Dobson’s realtor.

Impressed by improvements Dobson made to her own home, the realtor occasionally

asked Dobson to perform repairs or improvements for the houses she was listing.

When Archibald and Dobson began discussing the hardwood refinishing

project, Archibald asked about Dobson’s work experience. Dobson explained that

she did this type of construction and repair work when not working full time as a

longshoreman, though it is unclear whether she ever claimed to be registered as a

contractor. Archibald specifically wanted Dobson to use a Rubio Monocoat finish

for the project. Dobson had never used that finish before. She typically used

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. Dobson v. Archibald No. 100862-7

polyurethane finish, which is applied using a very different procedure. Despite her

inexperience, Dobson agreed to use Rubio Monocoat at Archibald’s insistence.

Archibald claims that Dobson was not forthcoming about her lack of experience with

the requested finish.

While Archibald was looking for someone to refinish his floors, he also got a

quote from a professional company for $4,321.40, which appears to include the costs

of preparation and materials in the approximate amount of $1,000.00. Archibald

chose to hire Dobson, and they agreed that Dobson would do the work for $3,200.00.

Archibald paid Dobson a $700.00 deposit before the work began, and he purchased

the materials for the job for $579.22. The $700.00 deposit was factored into the

$3,200.00 total, but the $579.22 for the cost of materials was not—this was

additional money out of Archibald’s pocket.

Dobson completed the work during her off-hours from working as a

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