Pay Transparency Compliance Missteps Lead to $900K Payout

A $900,000 settlement in Washington shows how easily employers can stumble on pay transparency compliance when job postings lack required pay ranges.

The Washington case centers on Domino’s franchisees accused of leaving pay range details out of job postings, an omission that violated the state’s pay transparency rules and led to a costly class action settlement.

Wage Transparency Lawsuit Is Filed

In the case, three Domino’s Pizza defendants agreed to pay $900,000 to settle a class action suit that accused them of violating the Washington Pay and Equal Opportunities Act, which took effect at the start of 2023.

The suit said the defendants broke the law when they declined to include wage scales or salary ranges in job postings for Washington-based positions, as the state law requires.

It added that pay range disclosures “correct information asymmetry” and help job candidates achieve equal pay. It also cited research that, according to the suit, revealed pay disparities with respect to women and other protected classes as well. It pointed to a study that found women are paid 78  cents for every dollar that is paid to men.

Applicant Says Job Posting Lacked Required Info

Peter Corwin, who lives and Washington and applied for a job with a Washington Domino’s, was the original named plaintiff in the suit. He says that when he applied in February of this year, the job posting did not disclose the wage scale or salary range that was being offered.

As the named plaintiff in the class action suit, he sued on behalf of himself and all others who were similarly situated. The suit says that since the state law took effect, more than 40 class members applied for jobs via postings that lacked the salary-related information that the law requires. The settlement agreement that resolves the suit estimates that the total number of class members is 6,538.

The suit says that when it was filed in February of this year, the defendants were continuing to withhold required pay-related information from job postings.

As relief, it asked for statutory damages of $5,000 per class member. It also sought the costs of suit and attorneys’ fees. Finally, it requested injunctive relief that would require the defendants to post the required salary-related information.

The case highlights how pay transparency compliance isn’t just a legal formality but a daily operational check for HR teams. Missing or inconsistent postings can trigger class action exposure and invite state scrutiny.

Agreement Resolves Wage Transparency Lawsuit

To end the case, the parties entered into a settlement agreement that the parties signed in July and August of this year.

The agreement, in which the defendants explicitly deny wrongdoing, calls for a payment by the defendants’ insurer of $900,000 to a settlement fund.

Of that amount, approximately one-third ($299,997) will go toward attorneys’ fees. Another $5,000 is allocated for costs and expenses, while Corwin and four later-added named plaintiffs will each get $10,000. In addition, up to $20,000 is allocated for costs incurred by the settlement administrator.

Those allocations leave about $95 for each of the estimated 6,538 class members.

In late August, the court issued an order that preliminarily approved the settlement. In the order, it preliminarily certified the settlement class and approved the settlement fund amount.

It also reiterated that the settlement agreement is not to be interpreted as an admission of guilt on the part of the defendants.

Action Steps for HR Leaders

Recruiters and HR leaders should treat wage range disclosures as a required pay transparency compliance checkpoint, not just a best practice. Each job posting must include clear wage information aligned with applicable state laws to avoid costly class actions like the Washington case.

Beyond legal protection, consistent disclosure helps build trust with applicants and supports broader pay equity goals.

Understanding Pay Transparency Compliance

Generally speaking, pay transparency compliance requires employers to share information regarding compensation with applicants – and sometimes with employees. Their goal is to reduce pay inequities and promote fairness with respect to pay.

While the subject is not federally regulated, many states and localities have their own versions of pay transparency laws. These laws have varying requirements.

Explore our pay transparency compliance guide for a state-by-state overview, and review these pay transparency best practices for practical steps HR can take.

Corwin v. Jeff, Pat, Chris, LLC, No. 25-2-05696-1 SEA (Wash. Super. Ct.).