A question left open in Stoel Rives’ recent Washington lien law treatise relates to the lien rights of employee benefit plans. The rights granted in RCW 60.04.011(4) (where benefit plans are included in the definition of “furnishing labor”) were called into question by two Washington Supreme Court decisions barring employee benefit plans from pursuing lien-like remedies on public projects because such rights were preempted by ERISA.  The Washington Supreme Court recently overruled those two earlier decisions on this issue, citing changes in governing federal law.  See W.G. Clark Constr. Co. v. Pac. Nw. Reg’l Council of Carpenters, 180 Wn.2d 54 (2014).  This new ruling should clear the way for employee benefit plans to pursue lien-like remedies on public projects (claims against bond and retainage) and traditional lien remedies on private projects.