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DeReggi is Murphy v. Campbell Investment Co – Case Brief Summary (Washington)

In DeReggi is Murphy v. Campbell Investment Co., 79 Wn.2d 417, 486 P.2d 1080 (Wash. 1971), a contractor applied for a license, but the application was rejected because the contractor failed to include proof of liability and property damage insurance (although in fact the contractor had such insurance). Id. at 1081.

At the same time, the contractor was negotiating a contract with a property owner to provide labor, materials, and equipment for a construction project. Id.

The parties signed a contract, construction started immediately thereafter, and the contractor resubmitted its license application about three weeks after work started. The license was then promptly issued.

The Court held that substantial compliance with the licensing statute was shown inasmuch as the purpose of the statute was to "prevent the victimizing of a defenseless public by unreliable, fraudulent and incompetent contractors, many of whom operated a transient business from the relative safety of neighboring states." Id. at 1083.

The statute was written to ensure minimum financial security for the consumers who hire building contractors. Once again, the statutory purpose was fulfilled because the contractor had the required property and liability insurance and surety bond, and the license having been rejected due to a purely technical defect. Id.