The Washington Court of Appeals declined to apply that state’s family-member exception to a corporation that employed its owner’s family members. Patten v. Ackerman , 68 Wash.App. 831, 846 P.2d 567, 568–69 (1993). The Washington antidiscrimination statute defined "employer" to include a corporation that employs eight or more persons but "exclude[d] as employees any individual employed by his or her parents or spouse."
This is fundamentally distinct from a corporation. An individual is not personally responsible for a corporation's employees even if the corporation is closely held. Patten v. Ackerman, 68 Wash.App. 831, 834-35, 846 P.2d 567 (1993).¶17 Nor can a sole proprietorship qualify as an "artificial person."