Paula Peak, V. Dept. Of Labor & Industries

Court of Appeals of Washington·Decided August 3, 2026·No. 87862-0·Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

ARTHUR C. BEARD; and PAULA PEAK, surviving spouse of JAMES No. 87862-0-I LORKOWSKI,

Appellants, DIVISION ONE

v. UNPUBLISHED OPINION DEPARTMENT OF LABOR & INDUSTRIES, STATE OF WASHINGTON; and THE BOEING COMPANY,

Respondents.

CHUNG, J. — Petitioners Paula Peak, the surviving spouse of James Lorkowski,

and Arthur Beard challenge the reduction in workers’ compensation benefits under

RCW 51.32.067, .220, and .225. Both Lorkowski and Beard were determined to be

permanently and totally disabled under the “Industrial Insurance Act” (IIA), Title 51

RCW, and awarded pensions. Because each worker was married, they were also

required to elect a survivorship option for their pension under RCW 51.32.067. Their

elections resulted in reduced pension rates in exchange for survivorship benefits. Both

workers later became eligible for federal social security benefits once they reached

retirement age. As a result, the Department of Labor and Industries (Department)

reduced their pensions by the amount they were receiving in social security benefits.

Peak and Beard argue that according to the plain language of RCW 51.32.220(5), this No. 87862-0-I/2

reduced rate cannot go below their pre-actuarially reduced pension rates. We disagree

and affirm.

BACKGROUND

James Lorkowski sustained an injury in his course of employment with the

Boeing Company (Boeing). Lorkowski died in 2023 for reasons unrelated to his injury.

The Department had found Lorkowski was permanently and totally disabled, and

approved him for pension benefits effective August 16, 2020. The Department then sent

Lorkowski a letter informing him that because he was married, he could choose to

receive one of three options concerning his pension benefits: (1) “the full monthly

benefit minus any deductions” but his beneficiary “will not receive ongoing benefits after

[his] death”; (2) “a reduced monthly benefit” and if he died “from a cause unrelated to

[his] covered injury or illness, [his] beneficiary will receive the same level of benefit [he

was] receiving minus any deduction”; or (3) “a reduced monthly benefit” and if he “die[d]

from a cause unrelated to [his] covered injury or illness, [his] beneficiary will receive

50% of the benefit level [he was] receiving minus any deduction for the rest of [the

spouse’s] life.” On August 21, 2020, Lorkowski elected the second option.

Lorkowski began receiving social security retirement benefits in January 2021. In

July 2022 and February 2023, the Department issued orders reducing Lorkowski’s

pension benefits based on his simultaneous receipt of federal social security benefits.

On April 4, 2023, Lorkowski appealed the reduction to the Board of Industrial Insurance

Appeals (Board). Lorkowski passed away on April 5, 2023, and the Department

approved Peak’s application to claim his pension benefits.

2 No. 87862-0-I/3

Arthur Beard suffered an industrial injury in early January 2015. The Department

determined he was permanently and totally disabled and approved his pension benefits

on March 31, 2020. When prompted by the Department to select one of the three

options available to married workers, Beard selected option three, a reduced monthly

pension benefit so his spouse would receive a portion of the benefit if he died from a

cause unrelated to his covered injury.

On September 27, 2021, Beard reached the federal retirement age 1 and began

receiving social security retirement benefits rather than social security disability benefits.

Accordingly, in October 2021, the Department issued an order adjusting Beard’s

pension compensation effective November 16, 2021. On February 2, 2023, Beard

appealed the adjustment to the Board.

In their respective appeals to the Board, both Peak and Beard argued that the

Department’s adjustments were incorrect because the “offset should be based . . . on

[the worker’s] time loss compensation rate notwithstanding any reduction for surviving

spouse election.” Peak and Beard both moved for summary judgment based upon

stipulated facts. The Board disagreed with Peak and Beard’s reading of the relevant

statutes and affirmed the Department’s decisions as a matter of law. Peak and Beard

appealed their Board decisions to the superior court and filed a stipulated motion to

consolidate the cases, which the court granted.

The superior court granted summary judgment in favor of the Department. Peak

and Beard timely appealed to this court.

1 42 U.S.C. § 416(l).

3 No. 87862-0-I/4

DISCUSSION

I. Appeal of Order Granting Summary Judgment to the Department

Peak and Beard contend that the Department cannot reduce their benefits below

the rate they were receiving before they elected for survivorship rights. They base this

argument on the plain language of RCW 51.32.220(5), which allows the Department to

reduce pension benefits once a worker begins receiving social security benefits, but not

below “the greater amount the worker may be entitled to” under the IIA or the SSA. The

Department disagrees, 2 arguing that related statutes require application of the

survivorship reduction before the social security offset. And, it argues, the phrase in

RCW 51.32.220(5)—“may be entitled to”—refers to the amount the IIA “provides in all of

its provisions,” including actuarial reductions. Thus, the Department contends that “for a

worker who has elected to undergo an actuarial reduction, the actuarially reduced

benefit is the benefit the worker may be entitled to receive under the [IIA].”

The IIA, Title 51 RCW, governs judicial review of worker’s compensation

decisions. Smith v. Dep’t of Lab. & Indus., 22 Wn. App. 2d 500, 506, 512 P.3d 566

(2022). On appeal, the appellate court reviews the superior court’s decision, not the

Board’s order. Id.; RCW 51.52.140. “We review the superior court’s decision in the

same manner as other civil cases.” Id. We review summary judgment orders de novo.

Sartin v. Est. of McPike, 15 Wn. App. 2d 163, 172, 475 P.3d 522 (2020). Summary

judgment is appropriate if no genuine issues of material fact are present and the moving

party is entitled to judgment as a matter of law. See CR 56(c). While “[w]e may

substitute our own judgment for that of the agency regarding issues of law, . . we give

2 Boeing’s briefing on appeal contains minimal argument and states that it “aligns” with the

Department’s arguments.

4 No. 87862-0-I/5

great weight to the agency’s interpretation of the law it administers.” Bennerstrom v.

Dep’t of Lab. & Indus., 120 Wn. App.

Free access — add to your briefcase to read the full text and ask questions with AI

Paula Peak, V. Dept. Of Labor & Industries, (Wash. Ct. App. 2026).

Paula Peak, V. Dept. Of Labor & Industries (Paula Peak, V. Dept. Of Labor & Industries) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Reesor v. Montana State Fund
2004 MT 370 (Montana Supreme Court, 2004)
Seven Gables Corp. v. MGM/UA Entertainment Co.
721 P.2d 1 (Washington Supreme Court, 1986)
Herzog v. Department of Labor & Industries
696 P.2d 1247 (Court of Appeals of Washington, 1985)
Hubbard v. Department of Labor & Industries
992 P.2d 1002 (Washington Supreme Court, 2000)
State v. Hahn
924 P.2d 392 (Court of Appeals of Washington, 1996)
State Ex Rel. Boan v. Richardson
482 S.E.2d 162 (West Virginia Supreme Court, 1996)
Seattle School District No. 1 v. Department of Labor & Industries
804 P.2d 621 (Washington Supreme Court, 1991)
Ravsten v. Department of Labor & Industries
736 P.2d 265 (Washington Supreme Court, 1987)
Duke v. Boyd
942 P.2d 351 (Washington Supreme Court, 1997)
Golden v. Westark Community College
969 S.W.2d 154 (Supreme Court of Arkansas, 1998)
Wal-Mart Stores, Inc. v. Keel
817 So. 2d 1 (Supreme Court of Louisiana, 2002)
Frazier v. Department of Labor & Industries
3 P.3d 221 (Court of Appeals of Washington, 2000)
Potter v. DEPARTMENT OF LABOR AND IND.
3 P.3d 229 (Court of Appeals of Washington, 2000)
1000 Virginia Ltd. Partnership v. Vertecs Corp.
146 P.3d 423 (Washington Supreme Court, 2006)
Merrill v. Utah Labor Commission
2009 UT 26 (Utah Supreme Court, 2009)
Bennerstrom v. DEPT. OF LABOR & INDUSTRIES
86 P.3d 826 (Court of Appeals of Washington, 2004)
Harris v. Department of Labor & Industries
843 P.2d 1056 (Washington Supreme Court, 1993)
John T. Scott, Dec'd v. Dept. Of L&i
442 P.3d 28 (Court of Appeals of Washington, 2019)
Christopher W. Sartin v. Alonzo Mcpike
475 P.3d 522 (Court of Appeals of Washington, 2020)
Duke v. Boyd
133 Wash. 2d 80 (Washington Supreme Court, 1997)