A federal bankruptcy judge in Seattle ruled on October 22, 2026 that a contractor's $129,948.72 debt to a homeowner survives bankruptcy. What the court found about a lumber bill, and what Washington asks of contractors.
On October 22, 2026, a federal bankruptcy court in Seattle ruled that a contractor's debt of $129,948.72 to a homeowner cannot be wiped out in the contractor's bankruptcy. The court found that the contractor knowingly made false statements about buying lumber and trusses, and that the homeowner justifiably relied on them. The false statements date from 2021. The ruling is new. It is a civil decision about a bill, not a criminal case, and it says nothing about a license or registration.
This article covers what the court found, what "cannot be wiped out" means, and what the ruling does and does not decide. It also covers what Washington's Department of Labor and Industries (L&I) asks of contractors. That matters for companies that want to work in Washington. We do not name the contractor, the homeowner or either company. For the full picture of how Washington registers contractors, start with the Washington contractor license page.
At a glance
- Who: a contractor and a homeowner. Not named here.
- Decided: October 22, 2026, by the U.S. Bankruptcy Court for the Western District of Washington, after a bench trial on June 22 and 23, 2026.
- The job: a custom home and shop in Idaho, under a contract signed September 24, 2021, with an estimated price of about $1.1 million.
- What the court found: the contractor knowingly made false statements about paying for lumber and trusses, and the homeowner justifiably relied on them.
- The order: a judgment of $129,948.72, plus interest at the federal judgment rate, that the bankruptcy cannot wipe out.
- What it is not: a criminal case. Nothing in the ruling is about a license or registration.
- The Washington tie: the court sits in Seattle and the company was a Washington limited liability company with its place of business in Idaho. The home was in Idaho.
What the court found
The contract was cost plus a fee. The company was to be paid monthly for work completed. Each bill was to cover the cost of the work done through the end of the month before, plus its share of the fee. A written summary of the invoices for labor and materials came with it. The court read the contract as allowing the company to bill for services and materials it actually provided. It noted that the contract's long list of what counts as cost of the work has no mention of estimated costs not yet incurred.
The homeowner paid a down payment on the day of signing, then two payments in November and December 2021. In all he paid $285,940.09, about 26 percent of the contract price.
The text and the bill
On October 31, 2021, the homeowner texted the contractor that he had read lumber prices were going up and asked whether they should be buying the siding. The contractor answered, in part: "Lumber is going up but we are already locked in. Bought it Tuesday."
Two days later the company sent its first bill. It listed a shop package at $15,270, framing at $71,350.54, and trusses and sheathing at $25,595.74, a total of $112,216.28 for materials. The backup invoices came from a lumber supplier. At the top of each was the word "QUOTATION," and the second ended with "THIS IS AN ESTIMATE ONLY." The contractor testified that he never did business with that supplier. He said he only got an estimate and never placed a deposit or paid the supplier anything.
The court found that the contractor told the homeowner several times that he had paid the supplier when he in fact never did. It found the homeowner believed the materials had been bought, and that he justifiably relied on that. The court said that even if he had seen the "quotation" and "estimate" labels, he justifiably relied on the contractor's word that the lumber was bought.
The papers sent as proof
Soon after the first payment the relationship went bad, and the homeowner came to believe the lumber had not been bought. He told the contractor that his wife needed to see proof of purchase. He admitted at trial that this was not true. His wife had made no such request, and he said it to get the contractor to send phony documents.
On December 3, 2021, the contractor emailed the second bill with what he called proof of payment for the trusses and the deposit on the lumber: two documents that appear to show wire transfers. At trial the contractor said he made these documents up: the amounts, the descriptions and the numbers that look like confirmation. He also said the homeowner had asked him to create them. The court found that account not credible. The court also found that when the homeowner paid the second bill, he already knew he could not trust the contractor. Any reliance on those papers was not reasonable.
What the court did and did not decide
The homeowner argued three false statements. The court accepted one.
- Accepted: the false statements about buying lumber and trusses. The court added the three materials lines and the company's fee on them to reach $129,948.72.
- Not accepted: that the contractor made false statements to get the homeowner to sign because the company could not or would not do the job. Photos showed substantial work, the contractor obtained engineering and environmental plans, and the homeowner's lawyers wrote in January 2022 that he had received materials and services.
- Not accepted: the second wire transfer document, because the homeowner could not show he justifiably relied on it.
- Not accepted: a claim that the debt was a willful and malicious injury. The court found the contractor made false statements to get payments, but not that he deliberately intended to injure the homeowner.
The court also did not award the whole first bill. It found the homeowner had not offered enough evidence of damages beyond the materials. It said the homeowner received some value from the remaining work and materials.
What "cannot be wiped out" means
The federal courts explain that "a bankruptcy discharge releases the debtor from personal liability for certain specified types of debts." Not every debt is released. Section 523(a) of the Bankruptcy Code lists exceptions. One is a debt "for money, property, services, or an extension, renewal, or refinancing of credit, to the extent obtained by false pretenses, a false representation, or actual fraud." For debts like this, the federal courts say creditors must ask the court to decide that they are excepted from discharge. Without that request and a ruling, they will be discharged.
The homeowner had to prove it, by a preponderance of the evidence. The court listed what that takes. The contractor made the statements and knew they were false when he made them. He made them to deceive. The homeowner relied on them and lost money as a result. The court noted that justifiable reliance is a lower standard than reasonable reliance and looks at the particular person and the circumstances.
This is a trial court's decision, and it directs the court to enter a judgment. We do not know whether anyone will appeal, how the judgment will be paid, or what comes next, and we do not guess.
What the ruling means for how you bill
None of what follows is a court rule. It is plain practice that follows from what the court described. General information, not legal advice.
- Read your own contract's payment terms. In this one, the court read them as allowing bills for work and materials actually provided.
- If you bill materials, attach the supplier's real invoice, not a quotation or an estimate.
- If a client asks for proof of purchase, send the real thing.
- If you want to bill ahead of buying, agree it with the client in the contract and in writing.
What Washington asks of contractors
The ruling is silent on licensing, and the job was in Idaho. Here is what L&I says for work in Washington.
L&I's contractor page says: "Washington State requires all construction contractors to register with L&I. State law also requires construction contractors to be bonded and insured to protect the public." Once registered, contractors can bid, advertise and perform construction work. L&I also says: "By law, when you advertise, solicit bids or offer to perform work, you must always include your contractor registration number. This includes business cards, Yellow Page ads, newspaper ads, internet ads, estimates and bid proposals." Registered businesses are listed in L&I's Verify a Contractor, Tradesperson, or Business tool, so a homeowner can look one up.
That is how a client trusts a contractor on paper. The registration number checks out. The bill matches the invoices behind it. The proof of payment is real. That is general practice, not something the court said.
For companies that want to work in Washington
Washington requires contractor registration, not an exam based license, for general and specialty contractors. It is issued to the business, tied to its state business number, with no qualifying individual. It rests on a surety bond, liability insurance and state business registration rather than trade exams or experience. Electrical and plumbing work use separate L&I credentials, with a certified electrical administrator, a master electrician or a designated plumber on staff. The Washington contractor license page lays out each path.
Washington general and specialty registration has no qualifier, so a qualifying agent is not how a company registers there. In many other states, a licensed qualifying agent who is a real employee of the company qualifies the company with the board. Contractor qualifier services explains how The Licensing Company helps with that. Whether an application is approved is up to the board, not a promise from anyone.
Frequently asked questions
Can a contractor erase a debt in bankruptcy? A discharge releases a debtor from many debts, but section 523(a) lists exceptions, including money obtained by "false pretenses, a false representation, or actual fraud." The creditor has to ask the court to decide, and has to prove it.
What did the court find about the lumber? That the contractor told the homeowner several times he had paid his lumber supplier when he never did. The court found he knowingly made false statements, and that the homeowner justifiably relied on them.
Was this a criminal case? No. It was a civil dispute inside a bankruptcy case. The judgment is money owed.
Was the contractor licensed or registered? The ruling does not say.
Does a contractor need to register to work in Washington? L&I says Washington requires all construction contractors to register with L&I. Electrical and plumbing work have separate L&I credentials.
How can a homeowner check a Washington contractor? Through L&I's Verify a Contractor, Tradesperson, or Business tool. L&I also says the contractor's registration number must be on advertising, bids and estimates.
This article is general education, not legal advice. L&I or a construction attorney can confirm how the law applies to a specific job.
Marshall Schofield, one of the nation's leading contractor exam prep instructors, has helped thousands upon thousands of contractors get licensed. Jeremiah Jaskulski is a licensed contractor who has lived the licensing process across multiple states. Together they founded The Licensing Company, and they help contractors get licensed the right way in Washington and nationwide. Sources: the Memorandum Decision and Order of the U.S. Bankruptcy Court for the Western District of Washington, entered October 22, 2026, 11 U.S.C. section 523, the United States Courts page on discharge in bankruptcy, and the Washington State Department of Labor and Industries contractor registration pages.
Disclaimer: This article is provided for educational and informational purposes only. It does not constitute legal advice, licensing guidance, or an offer of services. Licensing requirements vary by jurisdiction. For specific compliance questions, contact The Licensing Company for a confidential consultation.