Wash. Rev. Code § 4.16.080

For damage to real property arising from construction or activity on adjacent property, the three-year limitation in § 4.16.080(1) accrues when the first substantial injury is sustained if damage had not occurred when construction was completed.

Vern J. Oja & Associates v. Washington Park Towers, Inc. · filed 1977-08-29

The damages flowed from the pile driving as a whole and the cause of action accrued when the building was completed.

RCW 4.16.080's three-year limitations period for legal-malpractice claims begins when the client discovers, or with reasonable diligence should have discovered, the facts giving rise to the claim.

Streifel v. Hansch · filed 1985-04-09

It is not contested that the 3-year statute of limitation applies. RCW 4.16.080. ... In Peters v. Simmons, 87 Wn.2d 400, 406, 552 P.2d 1053 (1976), the court held: the statute of limitations for legal malpractice should not start to run until the client discovers, or in the exercise of reasonable diligence should have discovered the facts which give rise to his or her cause of action. ... It is readily apparent that by January 1980, the Hansches had discovered facts giving rise to an action, not only against the Charons but also the closing attorneys. Hence, their causes of action accrued at that time.

For a legal malpractice claim, RCW 4.16.080(3) imposes a three-year limitations period that accrues when the plaintiff’s legal interest is invaded, even if monetary damages are not yet certain.

Gill v. Hillier, Scheibmeir, Kelly & Satterfield · filed 2024-01-30(3)

The statute of limitations period for legal malpractice claims is three years. RCW 4.16.080(3); Huff, 125 Wn. App. at 729. The statute of limitations period “begins to accrue when the plaintiff has a right to seek legal relief.” ... We hold that the statute of limitations bars Gill’s claim. As Gill stated in his complaint, the injury—the invasion of his legal right—occurred when the Internal Revenue Service recorded its first tax lien against RG Construction. ... But this argument ignores that Gill’s legal interest, his ability to collect against RG Construction’s assets, was first invaded when the tax lien took priority because Gill’s interest was unsecured. Under Huff, it is the invasion of the legal interest that causes the statute of limitations to accrue. ... In either case, the injury occurred more than three years before Gill commenced the 2022 lawsuit. Therefore, we hold that the statute of limitations bars Gill’s legal malpractice claim.

Section 4.16.080(2)'s three-year limitations period does not govern a false-light invasion-of-privacy claim when the underlying facts also support defamation; the two-year defamation period applies.

Eastwood v. Cascade Broadcasting Co. · filed 1986-07-24(2)

The statute of limitations applied by Division Three in Eastwood reads: Actions limited to three years. Within three years: (2) An action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof, or for any other injury to the person or rights of another not hereinafter enumerated; RCW 4.16.080. ... We are persuaded that because of the duplication inherent in false light and defamation claims that the same statute of limitations is applicable to both actions. Accordingly, we hold that a false light invasion of privacy claim is governed by the 2-year statute of limitations for libel and slander, RCW 4.16.100(1).

Section 4.16.080(2) provides the three-year limitations period applicable to an action arising from an automobile accident, including an uninsured-motorist claim tied to that accident.

Gaddis v. Safeco Insurance · filed 1988-02-29(2)

The dispositive issue is whether a claim for uninsured motorist coverage for loss of consortium is governed by the 3-year statute of limitations applicable to an action on the underlying automobile accident, RCW 4.16.080(2), or the 6-year statute of limitations applicable to an action on the written insurance policy, RCW 4.16.040(1). Because Safeco, the insurer, stands in the shoes of Juttner, the uninsured motorist, State Farm Mut. Auto. Ins. Co. v. Bafus, 77 Wn.2d 720, 724, 466 P.2d 159 (1970), and the Gaddis children's cause of action against Juttner is subject to the 3-year statute of limitations, their claim against Safeco is likewise subject to the 3-year statute of limitations.

Section 4.16.080(3) imposes a three-year limitations period on claims for breach of oral contracts, generally running from the breach absent fraud or a fiduciary relationship.

McGowan v. Pillsbury Co. · filed 1989-03-13(3)

The McGowans’ claim is subject to a three-year statute of limitations for oral contracts. RCW 4.16.080(3). ... The period commences upon breach of the agreement, absent fraud or fiduciary relationship. ... The McGowans’ allege that Haagen-Dazs fraudulently concealed its breach, and they did not discover the breach until much later. The Court holds that for the purposes of this motion plaintiffs’ claim of breach of the alleged oral agreement concerning site selection and lease negotiation is timely under the three-year limitations period.

Subsection (3) provides a three-year limitations period for oral contracts, except for account receivables covered by subsection 4.16.040(2).

Tingey v. Haisch · filed 2005-08-18(3)

Except for an account receivable, RCW 4.16.080(3) provides that the statute of limitations for an oral contract is three years.

Section 4.16.080(3) gives oral-contract claims a three-year limitations period, while subsection (2) covers conversion and other injury-to-rights claims.

Heeb v. Warring · filed 2013-12-05(3) and (2)

Although actions for breach of written contracts have a six-year limitations period, RCW 4.16.040, actions for breach of an oral contract must be commenced within three years. RCW 4.16.080(3).

Section 4.16.080(3) gives actions on oral agreements a three-year limitations period; using parol evidence only to interpret a written contract does not change the six-year period.

Business Finance Corp. Resp. v. Victoria Knoll Apps. · filed 2016-05-23(3)

A three-year statute of limitations applies to actions on oral agreements. RCW 4.16.080(3).

Subsection (3) gives claims based on oral agreements a three-year statute of limitations.

Carey v. Bumstead · filed 2019-04-29(3)

The statute of limitations for an oral agreement is three years, RCW 4.16.080(3), while that for a written agreement is six years, RCW 4.16.040(1). Because the parties did not agree to begin revenue sharing until they entered into the Oral Agreement, the three year statute of limitations applies to this claim.

Section 4.16.080(3) gives oral-contract claims a three-year limitations period when the contract is not in writing.

McCracken v. Browne · filed 2020-01-13(3)

Washington’s limitations period for breach of oral contract is, with exceptions not applicable here, three years.

Section 4.16.080(3) imposes a three-year limitations period on oral contract actions; for a continuing-services contract, the limitations period begins when the services end.

Raner v. The Fun Pimps Entertainment LLC · filed 2024-04-10(3)

In Washington, a contract action is subject to a six-year statute of limitations if based on a written contract, RCW § 4.16.040(1), and a three-year statute of limitations for an oral contract, § 4.16.080(3). ... Accordingly, when a contract governing a working relationship does not provide a fixed end date for services, or provide that the worker will receive periodic payments at specific times before the services end, it is a contract for continuing services and the statute of limitations for a breach of contract action begins to run from the date the services ended. ... Because Raner’s lawsuit was filed the same day that The Fun Pimps fired him, Dkt. 111 ¶ 18, if the contract is one for continuing services, the statute of limitations would not bar Raner’s suit for any payments made under the contract.

Section 4.16.080's three-year limitations period does not apply to an insured's contractual UIM-benefits action against the insurer.

Safeco Insurance Co. v. Barcom · filed 1989-05-18

We are, however, thoroughly unpersuaded that the parties agreed to displace the applicable contract statute of limitation based solely upon this language pertaining to coverage.

The three-year limitation period applies to wrongful-death claims based on medical malpractice and runs from the date of death.

Wills v. Kirkpatrick · filed 1990-01-29(2)

We conclude that the 3-year limitation period of RCW 4.16.080(2), measured from the date of death, applies to this claim for wrongful death based on the alleged medical malpractice of Dr. Kirkpatrick.

Section 4.16.080(2) supplies the catchall three-year limitations period for wrongful-death claims, running from accrual.

Allen v. State · filed 1992-03-26(2)

Wrongful death actions are governed by the 3-year statute of limitations. ... (applying the "catchall" 3-year statute of limitations of RCW 4.16.080(2) for wrongful death claims). Consequently, a wrongful death action must be brought within 3 years of the date when the action accrues.

Section 4.16.080(3) imposes a three-year limitations period on claims arising from unwritten partnership agreements, beginning at dissolution or when the complaining partner is excluded from the partnership’s affairs.

Laue v. Estate of Elder · filed 2001-08-22(3)

Because Laue's partnership claim arises from an alleged partnership agreement that is unwritten, it is subject to a three-year statute of limitation. The statutory period does not begin to run until dissolution or the exclusion of the complaining partner from participating in the affairs of the partnership. RCW 4.16.080(3); Malnar, 128 Wash.2d at 529-530, 910 P.2d 455.

Section 4.16.080(2) imposes a three-year limitations period on Washington wrongful-death actions, running from the decedent’s death.

Atchison v. Great Western Malting Co. · filed 2007-08-30(2)

The statute of limitations for a wrongful death action in Washington is three years. See RCW 4.16.080(2); Beal, 134 Wn.2d 776. ... We have not retreated from the Dodson court’s holding, and the rule is well settled: wrongful death actions accrue at the time of death.

Section 4.16.080(2) provides a three-year limitations period for injury to the person or rights of another not otherwise enumerated, and that period applies to a wrongful-death claim for a child's death under RCW 4.24.010, running from the date of death.

Fast v. Kennewick Public Hospital District d/b/a Kennewick General Hospital · filed 2015-06-02(2)

Instead, actions for wrongful death have long been held to be subject to the three-year limitations period provided by RCW 4.16.080(2) for "injury to the person or rights of another, not hereinafter enumerated." ... A wrongful death action accrues, and the time for filing begins, at the time of death. ... The trial court correctly applied the general tort statute of limitations to the Fasts' claim under RCW 4.24.010.

Section 4.16.080(2) imposes a three-year limitations period on wrongful-death claims.

In Re The Estate Of Heinz Gerhard Schneider · filed 2015-11-23(2)

The general three-year statute of limitations applies to wrongful death claims.

Subsection (2) supplies Washington’s three-year limitations period for § 1983 claims because it is the state’s general or residual personal-injury statute.

Calhoun v. Pierce County · filed 2021-01-20(2)

Specifically, they borrow the state’s “general or residual statute for personal injury actions.” Owens v Okure, 488 U.S. 235. 250 (1989). In Washington, that statute is RCW 4.16.080(2), which is a three-year limitations period. Bagley v CMC Realty Corp., 923 F.2d 758, 760 (9th Cir. 1991). Therefore, in this District, the limitations period for a §1983 claim is three years.

Section 4.16.080(2) supplies a three-year catch-all limitations period for wrongful-death claims when no more specific statute applies.

Smalls v. City of Tacoma · filed 2023-04-25(2)

This period comes from the so-called “catch-all” provision at RCW 4.16.080(2), which provides a three-year limitation on claims for “[a]n action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof, or for any other injury to the person or rights of another not hereinafter enumerated.” ... Because there is no statute of limitations “hereinafter enumerated” for wrongful death claims, the three-year catch-all provision applies. ... Accordingly, the Court holds that Plaintiffs’ wrongful death claims set forth in their Fifth and Sixth Claims for Relief are governed by the three-year statute of limitations of RCW 4.16.080(2), and Defendants’ motion to dismiss on the grounds that the statute of limitations has run is denied.

Section 4.16.080 provides a three-year limitations period for tortious-interference actions, but a tortious-interference claim based on the same injury as defamation is governed by defamation’s two-year period.

Helping Hands Support Services v. Destiny 508 · filed 2025-11-03

In Washington, the statute of limitations is two years on defamation actions, RCW 4.16.100, and three years on tortious interference actions, RCW 4.16.080; City of Seattle v. Blume, 134 Wn.2d 243, 251 (1997). ... Legacy 508’s tortious interference claim is premised entirely on the alleged defamation. It asserts the same injury for both claims—that HHSS’s “false and disparaging statements” were intended to interfere with Legacy 508’s business relationships and caused harm to Legacy 508’s reputation, business, and profits. Dkt. 62 at 36–37. The Court concludes the tortious interference claim is governed by the two-year limitations period applicable to the defamation claim.

Section 4.16.080(2) supplies a three-year limitations period for § 1983 claims brought in Washington.

Lemmon v. Pierce County · filed 2023-01-13(2)

Washington Revised Code § 4.16.080(2) articulates the relevant statute of limitations. ... Under the statute, “An action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof, or for any other injury to the person or rights of another not hereinafter enumerated . . . shall be commenced within three years.”

Section 4.16.080(2) generally gives wrongful death claims three years from the date of death, but claims based on negligent health care are governed by the medical negligence limitations statute instead.

Allyson Soocey, P.r. & Estate Of Steven Daryl Soocey v. Franciscan · filed 2020-10-20(2)

Applying Fast, which explicitly held that wrongful death claims based on negligent health care are governed by the medical negligence statute of limitations, not the general torts statute of limitations, we conclude that Soocey’s claim is barred because it was filed more than three years after the date of the alleged medical negligence.

Section 4.16.080(4) imposes a three-year limitations period on fraudulent-conveyance actions, running from discovery or when due diligence would have revealed the conveyance.

Aberdeen Federal Savings & Loan Ass'n v. Hanson · filed 1990-08-13(4)

The gravamen of the claim determines the applicable statute of limitation. ... The 3-year limitation of RCW 4.16.080(4) applies to fraudulent conveyance actions. ... In this step of the proceedings the gravamen of the claim is an action to set aside a purported fraudulent conveyance. Thus, the 3-year statute of limitations applies. ... The 3-year statute begins to run when the party discovered, or with the exercise of due diligence could have discovered, the existence of the fraudulent conveyance.

Section 4.16.080(2) supplies a three-year limitations period for trade name infringement claims and may serve as the analogous period for laches.

Bikila v. Vibram USA Inc. · filed 2016-10-31(2)

The analogous limitations period in Washington is three years, for trade name infringement. See RCW 4.16.080(2). The Bikilas did not file their claim within this period.

Subsection (2) supplies a three-year limitations period for the claims to which it applies.

Shelton v. Liquor and Cannabis Board of the State of Washington · filed 2022-07-08(2)

Actions brought pursuant to 42 U.S.C. § 1985 are governed by the forum state’s statute of limitations for personal injury actions. Taylor v. Regents of Univ. of Calif., 993 F.2d 710, 711–12 (9th Cir. 1993). As already stated, in Washington, that limitations period is three years. RCW 4.16.080(2). Plaintiffs’ potential § 1985 claims expired in 2019.

Section 4.16.080(3)'s three-year period does not govern an action on a written statutory bond when the underlying duty and liability arise from the bond; the six-year period applies.

Industrial Coatings Co. v. Fidelity & Deposit Co. of Maryland · filed 1991-10-03(3)

Fidelity's duty to "pay all laborers, mechanics, and subcontractors and materialmen" arises from the bond itself. This duty would exist regardless of the statute requiring the bond. Also, RCW 39.08 does not impose any liability on Fidelity; the only liability under the statute is that imposed on a public body that fails to require a bond. We conclude that Lybecker is controlling and that, because Industrial Coatings is a beneficiary of the Queen City-Fidelity contract, the applicable statute of limitation is 6 years. Therefore, we reverse the trial court's dismissal of Industrial Coatings' claim as time barred.

Section 4.16.080(3) provides a three-year limitation period for non-written contract-based actions.

BOGLE AND GATES v. Holly Mountain Resources · filed 2001-10-04(3)

RCW 4.16.080(3) provides a 3-year limitation period for non-written contract-based actions. ... For this reason, we conclude that RCW 4.16.080(3) applies to bar the action against Holly Mountain, and we affirm the trial court's summary judgment dismissal on this basis.

Section 4.16.080's three-year limitation applies to the counterclaim, and the court declined to toll or extend it under a continuing-relationship doctrine on these facts.

Seattle-First National Bank v. Siebol · filed 1992-02-25

The Siebols concede the 3-year limitation in RCW 4.16.080 applies to the counterclaim because Mr. Siebol knew in May 1983 the financing originally promised was not forthcoming. However, they seek an affirmative judgment exceeding Seafirst's claim, contending they fit within the "continuous relationship" doctrine which tolls the statute of limitation until the relationship between the parties is terminated. ... It did not involve bank loans. Nor do we find any cases from other jurisdictions which have applied the doctrine to a situation involving a commercial bank loan officer and a customer. We decline the invitation to adopt or extend the doctrine to these facts.

Section 4.16.080(2) provides a three-year limitations period for RCW 49.60 actions, but damages may be recovered for discrimination that began before the period if it continued into the limitations period.

Martini v. Boeing Co. · filed 1997-10-13(2)

The three-year statute of limitations of RCW 4.16.080(2) applies to actions under RCW 49.60. ... In Goodman, we held that an employee may recover damages for discrimination that begins during the period barred by the statute of limitations but that continues into the three-year limitations period. ... In Goodman, we concluded that the evidence there showed a continuing series of acts of discrimination that included acts before the limitations period as well as after it. Damages were accordingly awarded for all acts because they constituted a continuing violation. The same is true here.

Section 4.16.080(2)'s three-year personal-injury limitations period is extended by the claim statute's 60-day tolling period, so an action filed within three years and 60 days is timely.

Estate of Connelly v. Snohomish County Public Utility District No. 1 · filed 2008-07-21(2)

Consequently, the estate had three years and 60 days to file its lawsuit. Because the estate filed its lawsuit prior to this deadline, its suit was timely commenced and the trial court erred in dismissing its claims against the district.

The subsection (2) limitations period may be equitably tolled when justice requires and the claimant was diligent.

Hahn v. Waddington · filed 2017-06-05(2)

Washington law mandates equitable tolling when, as here, “justice requires.”

For a discrimination claim, the three-year limitations period accrues when the accommodation decision is officially denied and communicated to the claimant.

Albright v. State · filed 1992-04-06(2)

We find, under the preceding authority, that the statute of limitations did not accrue until February 23, 1984, when Albright's request for an accommodation was officially denied and communicated to him.

Section 4.16.080(2)'s three-year limitation for an injury to the person or rights of another begins to run on a handicap-discrimination claim when the employer decides not to accommodate the handicap and communicates that decision.

Hinman v. Yakima School District No. 7 · filed 1993-04-20(2)

The parties agree the 3-year limitation period established by RCW 4.16.080(2) applies to Ms. Hinman's claim of handicap discrimination. ... A cause of action for handicap discrimination accrues when the employer makes a decision not to accommodate the employee's handicap and that decision is communicated to the employee. ... Based on Albright, Boyd, and Douchette, Ms. Hinman's cause of action accrued when she returned to Davis High School in the fall of 1985. Since her lawsuit was commenced in October 1987, it was well within the 3-year limitation period.

Section 4.16.080(2) supplies a three-year limitations period for chapter 49.60 claims, and conduct outside that period is barred unless a continuing violation applies.

Washington v. Boeing Co. · filed 2000-12-04(2)

Because Washington claims she was constructively discharged due to her sex and race in violation of chapter 49.60 RCW, the three-year statute of limitation applies to bar conduct that occurred prior to her transfer to the flight line.

RCW 4.16.080(3) imposes a three-year limitation period on refund claims based on unwritten express or implied liability, while RCW 4.16.080(2) supplies the three-year personal-injury limitation period for § 1983 claims.

Robinson v. City of Seattle · filed 1992-05-14(3), (2)

Accordingly, we hold that to the extent relief is available to the plaintiffs on a basis other than the federal statutory civil rights relief of section 1983 (i.e., if the plaintiffs are unsuccessful in their section 1983 action or seek refunds for payments made prior to declarations of ordinance invalidity), the 3-year statute of limitation of RCW 4.16.080(3) properly applies to the Robinsons' claims. ... The statute of limitation for personal injury actions in the state of Washington is 3 years under RCW 4.16.080(2). ... Thus the 3-year limitation period for personal injuries under Washington law applies to this section 1983 action.

Section 4.16.080's three-year limitations period applies to a liability-insurance claim when the insurer's obligation stems from the covered person's tortious act rather than from a contractual obligation to the claimant.

Rones v. Safeco Ins. Co. of America · filed 1992-09-10

The primary issue presented by this appeal is whether the 3-year statute of limitation for torts, RCW 4.16.080, or the 6-year statute for contracts, RCW 4.16.040(1), applies to Rones' action against Safeco. ... The second Barcom inquiry, whether any contractual language displaces the applicable statute of limitation, also supports application of the 3-year tort limitations period. ... Therefore, the applicable 3-year statute remains in place.

RCW 4.16.080(2) imposes a three-year limitations period on actions alleging violations of personal rights under RCW 49.60.

Goodman v. Boeing Company · filed 1994-07-25(2)

An action alleging a violation of personal rights established by RCW 49.60 must be brought within the 3-year limitation period established by RCW 4.16.080(2).

Section 4.16.080(2) provides the applicable three-year limitations period for the claims at issue, including federal claims borrowing Washington’s personal-injury period.

Conway v. Standard Insurance · filed 1998-08-04(2)

When a federal cause of action does not contain its own statute of limitations, courts borrow the most analogous state limitations period. ... In Washington, the period is three years. RCW § 4.16.080(2). ... In sum, the three year statute applies to all claims, but even if the six-year statute were applied, only the ADA claims would arguably survive assuming, as does plaintiff, that they , accrued on the effective date of the Act.

Section 4.16.080(2) supplies a three-year limitations period for section 1983 actions filed in Washington.

Carper v. Washington State Department of Corrections · filed 2010-01-22(2)

The district court properly dismissed the action against Whatcom County Jail because it was filed well after the applicable three-year statute of limitations had expired.

The three-year personal-injury limitations period was not equitably estopped on the facts of this section 1983 action.

Safouane v. Hassett · filed 2013-04-03(2)

The Safouanes have not alleged a basis for equitably estopping the defendants from asserting a statute of limitations defense.

Section 4.16.080(3) supplies a three-year limitations period for tax-refund claims.

New Cingular Wireless Pcs Llc v. City Of Bothell · filed 2014-08-25(3)

Washington courts apply a three-year statute of limitations to tax refund claims.

Subsection (2) supplies the three-year personal-injury limitations period for section 1983 claims.

Dunn v. City of Seattle · filed 2019-10-31(2)

Because 42 U.S.C. § 1983 does not contain a statute of limitations, the court applies Washington’s statute of limitations for personal injury actions and Washington’s law on equitable tolling to Mr. Dunn’s Section 1983 claims.

Subsections (2) and (3) impose three-year limitations periods on conversion and unjust-enrichment claims, accruing when the claims arose.

Dunn v. Bremerton Pilots Association · filed 2019-11-05(2) (3)

The estate’s claim against BPA accrued in December 2013, and therefore that the statutes of limitations bar Dunn’s claims for conversion and unjust enrichment.

Section 4.16.080(2) provides a three-year limitations period for personal-injury claims, including federal civil-rights claims in Washington.

Pierson v. Hudson Insurance Company · filed 2020-02-06(2)

Washington has a personal injury statute of limitations of three years. Wash Rev. Code § 4.16.080.

Section 4.16.080(2) imposes a three-year limitations period on federal civil-rights claims, including claims under 42 U.S.C. § 1983.

Donald Berg Et Ano v. City Of Kent · filed 2021-01-19(2)

In Washington, federal civil rights claims, such as the Bergs’ 42 U.S.C. § 1983 claims here, are subject to a three year statute of limitations.

Section 4.16.080(2) provides a three-year limitations period for personal-injury claims, which the court applied to the plaintiff’s § 1983 claims.

LaGroue v. State of Washington · filed 2020-02-18(2)

Thus, the applicable limitations period for Plaintiff’s claims is three years. Wash. Rev. Code § 4.16.080(2).

Section 4.16.080 provides a three-year limitations period for personal-injury claims, which Washington courts apply to civil-rights claims.

Kenneth Taylor Curry, V. Vancouver Housing Authority · filed 2022-06-14

However, when a plaintiff asserts causes of action based on civil rights violations, courts apply the state’s personal injury statute of limitations. Wallace v. Kato, 549 U.S. 384, 384, 127 S. Ct. 1091, 166 L. Ed. 2d 973 (2007). Washington’s statute of limitations for personal injury is three years. RCW 4.16.080. Additionally, discrimination claims made under the Washington Law Against Discrimination (WLAD), chapter 49.60 RCW, are subject to the three-year limitation period. Antonius v. King County, 153 Wn.2d 256, 261, 103 P.3d 729 (2004). ... However, Curry’s other causes of action are barred because they fall under a three-year statute of limitations. Curry alleged due process violations and disability discrimination. Because these are civil rights and WLAD claims, they fall under the three-year statute of limitations. And because these claims were filed three years after the statute of limitations began to run, they are barred, and Respondents’ defense prevails on these claims.

Section 4.16.080(2) is Washington’s residual personal-injury limitations statute, providing a three-year period that federal courts borrow for § 1983 claims.

Dufresne v. City of Bainbridge Island · filed 2022-12-22(2)

In Washington, that statute is RCW 4.16.080(2), which provides a three-year limitations period. ... Therefore, in this District, the limitations period for a §1983 claim is three years.

Section 4.16.080(2) supplies Washington’s general or residual three-year limitations period for personal-injury claims borrowed for § 1983 actions.

Fowler v. Guerin · filed 2023-05-19(2)

In Washington, that statute is RCW 4.16.080(2), which is a three-year limitations period. ... Therefore, in this District, the limitations period for a § 1983 claim is three years.

Section 4.16.080(2) supplies Washington’s three-year limitations period for personal-injury claims and is the limitations period borrowed for § 1983 claims.

Benedict v. Pierce County · filed 2025-04-09(2)

In Washington, that statute is RCW 4.16.080(2), which provides a three-year limitations period. ... The limitations period for a § 1983 claim is therefore three years.

Subsection (2) supplies a three-year limitations period for a § 1983 claim under Washington law.

Beagle v. State of Wash., Dept. of Corrections · filed 1992-12-14(2)

We have held that the appropriate statute of limitations in a § 1983 action is the three-year limitation of Wash.Rev.Code § 4.16.080(2).

Section 4.16.080(2) supplies a general three-year limitations period for a Bivens claim under Washington law, accruing when the plaintiff knew or had reason to know of the injury.

Swackhammer v. Sheila Widnall, Secretary of the U.S. Department of the Air Force · filed 1997-07-21(2)

The statute of limitations for her Bivens1 claim is the general three-year statute of limitations under Washington law. See Wash.Rev.Code § 4.16.080(2); Owens v. Okure, 488 U.S. 235, 236, 109 S.Ct. 573, 574, 102 L.Ed.2d 594 (1989); Van Strum v. Lawn, 940 F.2d 406, 409-10 (9th Cir.1991). It commenced to run when Swackhammer knew or had reason to know of the injury which is the basis of her action.

Section 4.16.080(4) imposes a three-year limitation period on actions based on fraud and applies that period to misrepresentation claims.

Evergreen Community Development Association v. Columbia Associates · filed 1993-06-17(4)

The parties disagree which Washington statute of limitations applies. U.S. Bank argues that only the "catch-all," general injury statute, RCW § 4.16.080(2), covers this action whereas Columbia frames its argument mostly in terms of the statute for actions based "upon the ground of fraud", RCW § 4.16.080(4). Both statutes set three-year limitation periods, although each requires a slightly different doctrinal analysis. ... Clearly, the fraud statute governs Columbia's fraud claim. The same provision also applies to Columbia's negligent misrepresentation claim. Even if the "gist" of a complaint is negligence, not fraud or deceit, an action based on misrepresentations is an action for fraud in the context of statutes of limitations.

Section 4.16.080 imposes a three-year limitations period for fraud and misrepresentation claims, running when the plaintiff knows or should have known all essential elements of the cause of action.

Kloster v. Roberts · filed 2014-02-06

The Klosters filed the motion on May 1, 2008, after the running of the three· year statute of limitations for suits alleging fraud and misrepresentation. RCW 4.16.080. The statute of limitations commences to run when the plaintiff knows, or in the exercise of due diligence should have known, all the essential elements of the cause of action.

Section 4.16.080(3) provides a three-year limitations period for actions to recover invalid taxes and related fees or charges, but the majority held that LUPA procedures supersede that rule for impact-fee challenges treated as land use decisions.

James v. County of Kitsap · filed 2005-07-07(3)

We applied the three-year statute of limitations under RCW 4.16.080(3) prior to LUPA when no uniform procedure was in place to challenge the legality of impact fees. This conclusion is no longer viable in the wake of LUPA, which establishes uniform procedures and by its own terms is the "exclusive means of judicial review of land use decisions. . . ." RCW 36.70C.030(1) (emphasis added). Since we find that the County's imposition of impact fees as a condition on the issuance of a building permit is a land use decision, it necessarily follows that the procedures established by LUPA to challenge that decision dictate.

Subsection (3) provides a three-year limitations period for actions to recover invalid taxes, fees, or charges, but that period does not govern a LUPA challenge to a permit condition when LUPA supplies the applicable review procedure.

James v. Kitsap County · filed 2005-07-07(3)

In Henderson Homes, we held that a three-year statute of limitations applies to actions to recover invalid taxes under RCW 4.16.080(3) and “[t]he same principle applies to fees or charges, direct or indirect, on the subdivision of land when they do not comply with RCW 82.02.020.” 124 Wn.2d at 248. We applied the three-year statute of limitations under RCW 4.16.080(3) prior to LUPA when no uniform procedure was in place to challenge the legality of impact fees. This conclusion is no longer viable in the wake of LUPA, which establishes uniform procedures and by its own terms is the “exclusive means of judicial review of land use decisions . . . .” RCW 36.70C.030(1) (emphasis added).

Section 4.16.080’s otherwise applicable three-year limitation does not bar a claim when the defendant dies before it expires; the probate nonclaim periods govern, and the limitation is tolled until a personal representative is appointed.

Augustson v. Graham · filed 1995-05-22

RCW 11.40.011 need be read in conjunction with RCW 4.16.200 only when the decedent has died before the expiration of the otherwise applicable statute of limitation, here, RCW 4.16.080. ... But where a decedent’s death before the expiration of the applicable statute of limitation is the event which tolls the running of the limitation period until a personal representative is appointed, RCW 11.40.011 does not negate the tolling. ... Accordingly, we hold that because Varnson died before the expiration of the 3-year statute of limitation so that the only applicable statutes of limitation are those contained in the probate nonclaim chapter, and because none of those time limitations were exceeded here, the Augustson lawsuit was timely.

Section 4.16.080 provides a 3-year limitation period for an attorney malpractice claim when the claim is based on an independent attorney-client relationship and resulting damages.

Meryhew v. Gillingham · filed 1995-07-28

If Meryhew can establish this separate attorney-client relationship and breaches of the duty of care within that context with resultant damages to Liebel, we conclude that the claim would be governed by the 3-year attorney malpractice statute of limitation, RCW 4.16.080, rather than the probate statute of limitation, RCW 11.96.060(2).

Section 4.16.080(3) provides a three-year limitations period for attorney-malpractice actions, and the period may be tolled while the attorney continuously represents the client in the same matter.

HIPPLE v. McFadden · filed 2011-04-28(3)

The statute of limitations for attorney malpractice action is three years. ... The "continuous representation" rule tolls the statute of limitations until the end of an attorney's representation of a client in the same matter in which the alleged malpractice occurred. ... We hold that whether the statute of limitations tolled under the continuous representation rule is an appropriate determination for trial.

Subsection (3) imposes a three-year limitations period on attorney-malpractice actions, subject to applicable accrual and tolling rules.

Evelyn Plant Test. Trust & Jennifer Linth v. Carl Gay, Et Ux · filed 2015-09-22(3)

The statute of limitations for attorney malpractice action is three years.

Section 4.16.080 provides a general three-year limitations period for fraud claims, but that state period does not bind the federal government in an action under Washington's Conveyance Act.

United States v. Bacon · filed 1996-04-30

Actions under the Conveyance Act are governed by a general three-year statute of limitations for fraud claims. RCW 4.16.080; ... Because the state statute of limitations for actions under the Conveyance Act does not apply to the federal government, the applicable limitation is the ten-year federal statute of limitations governing tax assessment collection actions. 26 U.S.C. § 6502(a)(1).

For a timber-trespass action involving concealed wrongdoing, the limitations period begins when the plaintiff discovers or reasonably should have discovered the responsible party.

Allyn v. Boe · filed 1997-09-05(1)

We hold that the discovery rule applies to timber trespass actions at least where, as here, the defendant conceals his wrongdoing.

For an oral demand loan whose parties contemplated delayed repayment, the three-year limitations period begins when the borrower is demanded to repay, rather than when the loan is made.

Nilson v. Castle Rock School District · filed 1997-10-31(3)

The statute of limitations on an oral loan agreement is three years from the date the cause of action accrued. RCW 4.16.080(3); RCW 4;16.005. ... We hold that the three-year statutory period for repayment of the $2,700 balance did not commence to run until Nilson made demand for repayment of the balance on July 6, 1992.

Section 4.16.080(3) gives an oral loan agreement a three-year limitations period, with a demand loan accruing on demand or after a reasonable time.

Ortiz v. Inga Sterling · filed 2017-06-27(3)

The parties agree that the applicable limitations period on an oral loan agreement is the three-year period provided by RCW 4.16.080(3).

Section 4.16.080(3) imposes a three-year limitations period on an unwritten express or implied contract, and for a “when able” promise the claim accrues when the debtor is actually financially able to pay, regardless of the creditor’s awareness.

O'NEIL v. Estate of Murtha · filed 1997-12-08(3)

As the majority rule dictates, in cases where a debtor promises to pay “when able,” a cause of action accrues upon satisfaction of such condition; that is, at the time when the debtor is in fact financially able to repay the loan, regardless of whether the creditor is aware of such ability. See In re Clover’s Estate, 171 Kan. at 701-03. Thus, O’Neil’s cause of action accrued before May 1, 1992, and his claim of November 9, 1995 came too late under RCW 4.16.080(3). The trial court did not err in finding O’Neil’s claim barred by the statute of limitations.

Subsection 4.16.080(3) gives three years to sue on an oral loan agreement, beginning when the cause of action accrues; for a demand loan whose terms contemplate delayed repayment, accrual occurs when repayment is demanded.

Nilson v. Castle Rock School Dist. · filed 1997-12-19(3)

The statute of limitations on an oral loan agreement is three years from the date the cause of action accrued. RCW 4.16.080(3); RCW 4.16.005. ... We hold that the three-year statutory period for repayment of the $2,700 balance did not commence to run until Nilson made demand for repayment of the balance on July 6, 1992.

Section 4.16.080(3)'s three-year limitations period for oral contract actions on a demand loan does not begin until notice or demand for repayment, or until a reasonable time has elapsed.

In Re Marriage Of: Sohrab Moshiri, Resp. v. Delta Moshiri, App. · filed 2015-10-19(3)

Delta next asserts that the three-year statute of limitations on oral contracts bars Sohrab's claim on the alleged $30,000 loan. ... An oral loan agreement that does not specify a time or period for repayment is a demand loan. ... The statute of limitations on actions for repayment of demand loans "does not commence running until notice is given or demand is made, or until a reasonable time has elapsed." ... Delta did not present any evidence showing either that the alleged loan had a specified repayment date (in which case it would not be a demand loan) or that Sohrab demanded repayment more than three years before he filed his motion. Thus, Delta has not shown a genuine factual dispute about this affirmative defense warranting an evidentiary hearing. The statute of limitations does not bar Sohrab's claim for repayment.

Section 4.16.080(2) formerly supplied the general three-year limitations period for personal-injury claims, but it no longer governs medical-malpractice actions after section 4.16.350 was enacted.

Gunnier v. Yakima Heart Center, Inc. · filed 1998-04-16(2)

With enactment of RCW 4.16.350, former RCW 4.16.010, and RCW 4.16.080(2) no longer apply to such actions.

Section 4.16.080's three-year limitations period applies to civil actions filed directly in court, not administrative actions to correct LEOFF benefits.

Pasco v. Department of Retirement Systems · filed 2002-03-22

The City argues that the RCW 4.16.080 three-year statute of limitations for civil actions filed directly in court[8] prevented the Department from enrolling Andres in LEOFF Plan 1 in 1978. But this statute does not apply to administrative actions to correct LEOFF benefits.

The three-year limitation period for legal malpractice, including its discovery rule, does not necessarily bar a legal-malpractice or breach-of-fiduciary-duty defense to an attorney-fee accord.

Simburg, Ketter, Sheppard & Purdy, L.L.P. v. Olshan · filed 1999-11-08(3)

RCW 4.16.080(3) imposes a three year statute of limitations on legal malpractice actions. ... The statute of limitations and its discovery rule do not bar, by necessity, a defense of legal malpractice and breach of fiduciary duties to an accord for attorney fees. Therefore, an expert’s opinion, rendered five years after an accord for attorney fees, may constitute facts to support a defense to the fee accord.

Section 4.16.080(3) provides a three-year limitations period for legal-malpractice actions, but its limitations period and discovery rule do not necessarily bar malpractice or fiduciary-duty defenses to an attorney-fee accord.

Simburg, Better, Sheppard & Purdy, L.L.P. v. Olshan · filed 1999-11-15(3)

RCW 4.16.080(3) imposes a three-year statute of limitations on legal malpractice actions. This court has ruled that RCW 4.16.080 governs a claim against an attorney for breach of fiduciary duty. ... The discovery rule, however, is not a substantive rule of law. Allowing the discovery rule to apply to legal malpractice defenses would allow an attorney to wait until the statute of limitations has run before pursuing recovery of his fees. By running the statute of limitations, the attorney may preclude the client from raising a legal malpractice defense to a claim for undeserved fees. The statute of limitations and its discovery rule do not bar, by necessity, a defense of legal malpractice and breach of fiduciary duties to an accord for attorney fees.

For a wrongful-death action, the three-year limitations period is tolled when there is no proof of death until the plaintiff can present evidence of death through the statutory or common-law presumption.

Nelson v. Schubert · filed 2000-01-03

We therefore hold that where there is no proof of death, the three-year statute of limitations for wrongful death actions is tolled until the plaintiff can present evidence of death by way of the presumption created in our statutes and common law.

Subsection (2) provides a three-year limitations period for tort claims, including product-liability, wrongful-death, and negligence claims, with accrual governed here by the discovery rule.

Clare v. Saberhagen Holdings, Inc. · filed 2005-02-07(2)

RCW 4.16.080(2) sets a three-year statute of limitations for torts, which includes product liability actions. Generally, accrual of the statute of limitations begins at the time the act or omission causing the tort injury occurs. The complaint includes causes of action for wrongful death and negligence which are also subject to the three-year statute of limitations. Here, accrual of the statute of limitations is governed by the discovery rule.

Section 4.16.080(4) gives tort claims, including fraud claims, a three-year statute of limitations, and continuing torts remain timely while they continue.

Alaska Airlines Inc v. Carey · filed 2010-09-16(4)

Alaska Airlines’s complaint, filed on December 27, 2007, raised allegations that were not time barred. Wash. Rev. Code § 4.16.080(4) (three year statute of limitations tort claims, including fraud); § 19.86.120 (four year statute of limitations for Consumer Protection Act claims). Carey was committing continuing torts, right through this litigation.

Section 4.16.080(2) requires personal injury claims to be commenced within three years after the alleged injury.

Kayongo v. Westfield, Llc. · filed 2015-07-27(2)

Personal injury claims must be commenced within three years of the date of the alleged injury. RCW 4.16.080(2). ... The court did not err in granting Westfield's motion for summary judgment on the ground that Kayongo's claim was barred by the statute of limitations.

Section 4.16.080(3) supplies three-year limitations periods for unjust-enrichment and indemnity claims, with accrual when the cause of action arises.

Joseph Mojarrad & Nicole Ching v. Walden · filed 2016-12-19(3)

These claims are subject to three-year statutes of limitations. RCW 4.16.080; ... A statute of limitations does not begin to run until the cause of action accrues—that is, when the plaintiff has a right to seek relief in courts.

Section 4.16.080(2) gives negligence actions a three-year limitations period that begins when the cause of action accrues and may be tolled until the plaintiff knows or should know the facts necessary to establish the claim.

Michael & Myrna Darland v. Snoqualmie Pass Util. Dist. · filed 2019-07-16(2)

The statute of limitations for a negligence action is three years. RCW 4.16.080(2). The statute of limitation period begins to run when the plaintiff’s cause of action accrues. Giraud v. Quincy Farm & Chemical, 102 Wn. App. 443, 449, 6 P.3d 104 (2000). Usually, the cause of action accrues when the plaintiff suffers injury, however, the three year limitations period is tolled “until the plaintiff knows or, through the exercise of due diligence, should have known all the facts necessary to establish a legal claim.” Giraud v. Quincy Farm & Chemical, 102 Wn. App. at 449.

Section 4.16.080(3) imposes a three-year statute of limitations on claims based on oral contracts, including an oral-contract defense asserted in the foreclosure dispute.

Meppelink v. Wilmington Savings Fund Society FSB · filed 2020-03-10(3)

Further, as pointed out by Wilmington, to the extent the Plaintiff is attempting to assert some sort of defense based on breach of an oral contract claim, Washington’s three-year statute of limitations on oral contracts, RCW 4.16.080(3), would bar her efforts.

Section 4.16.080(3) requires actions on unwritten express or implied contracts or liabilities to be commenced within three years of accrual; an implied-contract claim accrues when the evidence is sufficiently mature to establish its elements, not when the plaintiff realizes a legal claim exists.

Dougherty v. Pohlman · filed 2021-01-12(3)

Under RCW 4.16.080(3), “an action upon a contract or liability, express or implied, which is not in writing, and does not arise out of any written instrument” must be “commenced within three years” of accrual. ... As in Eckert, David’s cause of action fully matured when he completed his work on the home because it was susceptible of proof then. ... We reject this argument because an implied contract claim begins to accrue when the evidence of the claim is sufficiently matured to establish the elements in court, not the date when the plaintiff realizes they could bring a claim. ... In sum, we affirm the trial court’s dismissal of David’s claims because he did not bring them within the three-year statute of limitations.

Section 4.16.080 provides a three-year statute of limitations for a cause of action for alienation of a child’s affections.

Masood Abawi, Et Ano. v. Kiran Qureshi Aka · filed 2020-08-10

A cause of action for alienation of a child’s affections is subject to a three-year statute of limitations.

Section 4.16.080(2) imposes a three-year statute of limitations on tort and personal injury claims.

Shelton v. Liquor and Cannabis Board of the State of Washingt · filed 2024-02-20(2)

Washington imposes a three-year statute of limitations for tort and personal injury claims, Wash. Rev. Code § 4.16.080(2), and the same limitation applies to claims under 42 U.S.C. §§ 1981, 1983, 1985, Butler v. Nat’l Cmty. Renaissance of Cal., 766 F.3d 1191, 1198 (9th Cir. 2014) (§ 1983); Johnson v. Lucent Techs., Inc., 653 F.3d 1000, 1005-06 (9th Cir. 2011) (§ 1981); McDougal v. County of Imperial, 942 F.2d 668, 673-74 (9th Cir. 1991) (§ 1985).

Subsection (2) provides a three-year limitations period that applies to WLAD discrimination claims.

St Clair v. Okanogan County Washington · filed 2024-06-11(2)

Plaintiff’s claim is likewise time barred. Antonius v. King Cnty., 153 Wash. 2d 256, 261–62 (2004) (“WLAD does not contain its own limitations period. Discrimination claims must be brought within three years under the general three-year statute of limitations for personal injury actions.”).

Subsection (1) sets a three-year limitations period for trespass claims; the discovery-rule language quoted by Tacoma appears in subsection (6), which addresses different causes of action.

Day Island Yacht Club v. City of University Place · filed 2025-08-22(1)

But Tacoma misquotes the statute. As University Place points out in its reply, RCW 4.16.080(1) governs the statute of limitation for trespass claims, while Tacoma’s quoted language appears in subsection (6), which addresses entirely different causes of action. Dkt. No. 88 at 12 n.8. Under Washington law, trespass claims must be brought within three years and nuisance claims within two years. RCW 4.16.080(1); Wallace v. Lewis Cnty., 137 P.3d 101, 110 (Wash. 2006).

Section 4.16.080(2)'s three-year catch-all limitation period applies to Bivens claims arising in Washington.

Johnston v. Horne · filed 1989-05-25(2)

Washington has a similar catch-all provision. Wash.Rev.Code § 4.16.080(2) (1988). We hold that this three-year statute applies to Bivens claims arising in Washington.

Section 4.16.080(2) imposes a three-year limitation period on negligence and personal injury causes of action.

Gausvik v. Perez · filed 2004-12-13(2)

In its opinion of September 16, 2002, the district court found that Gausvik's state court claims — false imprisonment, intentional and negligent infliction of emotional distress, and negligent training and supervision by the City of Wenatchee — were time-barred by the Washington statutes of limitation. Gausvik, 239 F.Supp.2d at 1104-07. We affirm the district court's rulings on the state statutes of limitation. ... Gausvik's causes of action for false arrest and false imprisonment are time barred, Wash. Rev.Code § 4.16.100(1) (two-year limitation period), as are his causes of action for negligence and personal injury, Wash. Rev.Code § 4.16.080(2) (three-year limitation period).

For an unwritten partnership agreement, the three-year limitations period begins when the partnership is dissolved or the complaining partner is excluded from participating in the partnership’s affairs.

Laue v. Estate of Elder · filed 2001-05-21(3)

Because Laue’s partnership claim arises from an alleged partnership agreement that is unwritten, it is subject to a three-year statute of limitation. The statutory period does not begin to run until dissolution or the exclusion of the complaining partner from participating in the affairs of the partnership. RCW 4.16.080(3); Malnar, 128 Wn.2d at 529-30.

Section 4.16.080 gives bad-faith claims a three-year limitations period.

O'Neill v. Farmers Insurance · filed 2004-11-01

Under RCW 4.16.080, claims for bad faith are subject to a *530three-year statute of limitations.

Section 4.16.080(2) gives negligence claims a three-year statute of limitations.

Nash v. Chuck Atkins · filed 2020-11-16(2)

The statute of limitations for negligence claims is three years. RCW 4.16.080(2); Woods View II, LLC v. Kitsap County, 188 Wn. App. 1, 20, 352 P.3d 807 (2015).

Section 4.16.080(3) gives claims for overtime pay under the Washington Minimum Wage Act a three-year limitations period, even when an employment agreement generally promises compliance with state law.

Bennett v. Computer Task Group, Inc. · filed 2002-06-03(3)

The three-year statute of limitations applies to actions under the WMWA.[2] ... We hold that the trial court properly applied the three-year limitations period to bar Bennett's claim for overtime wages prior to June 16, 1997.

Section 4.16.080(2) sets a three-year limitations period for actions alleging injury to a person or another’s rights.

Massey v. MultiCare Health System · filed 2020-10-19(2)

As a result, the statutes of limitations for her claims have long since expired. See RCW 4.16.080(2) (three-year statute of limitations for any action alleging “injury to the person or rights of another”); RCW 4.16.100(1) (two-year statute of limitations for an action alleging assault or assault and battery).

Section 4.16.080(2)'s three-year period for personal-injury claims is not tolled for an independent cross claim by the plaintiff's lawsuit; the cross claim must be filed within the limitations period.

Rieger v. Bennett · filed 2004-02-09(2)

The statute of limitations on a defendant’s cross claim against a codefendant for her own personal injuries is not tolled by the commencement of the plaintiff’s lawsuit. ... In these circumstances a defendant must file a cross claim within the statute of limitations.

Section 4.16.080(1) sets a three-year statute of limitations for personal injury claims, which the court borrowed for the Title II claim.

Carter v. University of Washington School of Dentistry · filed 2022-08-22(1)

Because Title II does not specify a time limit for bringing an action, courts look to the state statute of limitations for personal injury actions. See 42 U.S.C. § 2000a-3; see also Soto v. Sweetman, 882 F.3d 865, 871 (9th Cir. 2018) (noting that because 42 U.S.C. § 1983 does not specify a statute of limitations, courts borrow the statute of limitations for state-law personal injury claims). Washington’s statute of limitations for personal injury claims is three years. See RCW 4.16.080(1).

For a WLAD hostile-work-environment claim, the three-year limitations period does not include a statutory discovery rule, and the entire unified hostile environment may be considered if one contributing act occurred within the period.

Antonius v. King County · filed 2004-12-23(2)

The County points out that the limitation period for RCW 4.16.080(2) is more than three times longer than for Title VII actions, which requires a claim with the EEOC to be filed within 300 days. ... The County maintains that under the three year statute of limitations of RCW 4.16.080(2) a “discovery rule” of accrual applies. ... Because we reject the continuing violation doctrine, we also reject the “substantial relationship” inquiry that constitutes part of the serial continuing violation inquiry, including its knowledge prong. Thus, we reject the argument that the statute of limitations commences to run when the plaintiff has notice of harm, however slight. ... And although, unless otherwise specified, RCW 4.16.005 bases the running of statutes of limitations on accrual of the cause of action, it does not contain a discovery rule. ... There is no statutory discovery rule of accrual that applies to hostile work environment claims. ... We agree, and accordingly decline to adopt a discovery rule of accrual for hostile work environment claims. ... In light of the rule of liberal construction and the purposes of the law prohibiting sex discrimination, we affirm the Court of Appeals and adopt Morgan's analysis for liability on a hostile work environment claim.

The three-year personal-injury limitations period applies to WLAD discrimination claims, but it does not include a statutory discovery rule for hostile-work-environment claims.

Antonius v. King County · filed 2005-02-04(2)

WLAD does not contain its own limitations period. Discrimination claims must be brought within three years under the general three-year statute of limitations for personal injury actions. RCW 4.16.080(2). ... And although, unless otherwise specified, RCW 4.16.005 bases the running of statutes of limitations on accrual of the cause of action, it does not contain a discovery rule. As noted, chapter 49.60 RCW does not contain a limitations period for civil causes of action and does not define accrual for such causes. There is no statutory discovery rule of accrual that applies to hostile work environment claims.

Section 4.16.080(2) supplies a three-year limitations period for the WLAD hostile-work-environment claim, which the court found timely when filed within that period.

Hallstrom v. Geeks Who Drink LLC · filed 2021-03-18(2)

claim was filed in May 2020, which was within the three-year statute of limitations under ... RCW 4.16.080(2).

Subsection (1)'s limitations period for continuing trespass limits recoverable damages to the three years preceding suit rather than barring the action.

Wallace v. Lewis County · filed 2006-06-20(1)

In the case of continuing trespass, the applicable statute of limitations does not preclude a property owner from bringing an action against the trespasser; rather, it serves only to limit damages. Bradley, 104 Wn.2d at 693; Fradkin, 96 Wn. App. at 126. Thus, this statute of limitations would limit Gee Cee’s damages to the three years preceding its timely-filed lawsuit.

Subsection (1) gives a plaintiff three years from the invasion to bring an intentional-trespass action.

Wallace v. Lewis County · filed 2006-08-15(1)

A plaintiff has three years from the date of invasion to bring an action for intentional trespass. RCW 4.16.080(1); Bradley, 104 Wash.2d at 692, 709 P.2d 782.

Section 4.16.080(1) limits recovery for continuing trespass to damages incurred from three years before filing through trial.

Woldson v. Woodhead · filed 2006-12-21(1)

We are asked to review the application of RCW 4.16.080(1) to the tort of continuing trespass. ... We conclude that the proper period for an award of damages for continuing trespass is three years before filing until the date of trial.

Section 4.16.080(2) provides a three-year limitations period for personal-injury claims, and subsection (4) provides a three-year limitations period for fraud claims.

Westway Const., Inc. v. Benton County · filed 2007-02-06(2) (4)

Because 42 U.S.C § 1983 does not have a specific statute of limitation, the U.S. Supreme Court has directed the lower federal courts to apply the general state law limitations period for personal injury claims. Cloud v. Summers, 98 Wash.App. 724, 733, 991 P.2d 1169 (1999). In Washington, this period is three years. See RCW 4.16.080(2); Conway v. Standard Ins. Co., 23 F.Supp.2d 1199, 1200 (E.D.Wash.1998). ... This claim is also barred by the statute of limitations because it was not pleaded until July 2004. See RCW 4.16.080(4) (fraud has three-year statute of limitations).

Section 4.16.080(2) provides a three-year limitations period for personal-injury claims, which applies to negligent-infliction and § 1983 claims.

Manning v. Washington · filed 2006-12-01(2)

To the extent that Mr. Manning asserts a claim for negligent infliction of emotional distress, that claim is governed by Washington’s three-year statute of limitations. See RCW 4.16.080(2); Gausvik v. Perez, 392 F.3d 1006, 1009 (9th Cir.2004). The complaint was filed within the three-year statute of limitations, and this claim is therefore timely. ... In deciding claims under Section 1983, federal courts borrow state statutes of limitations on a statewide basis. ... The Washington statute applicable to Section 1983 claims provides for a three-year statute of limitations. ... Mr. Manning’s Section 1983 claims are not barred by the statute of limitations.

Section 4.16.080(2) provides a three-year limitations period for personal-injury claims, including negligence and outrage or intentional-infliction claims.

Cox v. Oasis Physical Therapy, PLLC · filed 2009-11-17(2)

The three-year statute of limitations for personal injury actions governs Ms. Cox’s negligence claims. RCW 4.16.080(2). ... The claim is subject to a three-year statute of limitations. RCW 4.16.080(2); Milligan, 90 Wn. App. at 592.

Section 4.16.080(2) imposes a three-year limitations period on the plaintiff's action.

Phillips v. Maggie Miller · filed 2010-06-21(2)

The district court properly concluded that Phillips’s action is barred by the applicable three-year limitations period.

Section 4.16.080 provides a three-year statute of limitations for personal injury actions.

Robin Combs, Sr. v. Lehman · filed 2012-11-20

The district court properly dismissed as time-barred those claims for which Combs exhausted his administrative remedies more than three years before filing his complaint. See Wash. Rev. Code § 4.16.080 (three-year statute of limitations for personal injury actions); Brown v. Valoff, 422 F.3d 926, 943 (9th Cir. 2005) (“[T]he applicable statute of limitations must be tolled while a prisoner completes the mandatory exhaustion process.”); Jones, 393 F.3d at 927 (“For actions under 42 U.S.C. § 1983, courts apply the forum state’s statute of limitations for personal injury actions[.]”).

Section 4.16.080(2) provides a three-year statute of limitations for personal-injury actions, which applies to § 1983 claims in federal court through the forum state's limitations period.

Collins v. State of Washington · filed 2013-05-23(2)

The district properly granted summary judgment because Collins filed suit more than three years after his workers’ compensation claim closed in August 2007. See Wash. Rev. Code § 4.16.080(2) (three year statute of limitations for personal injury actions); Knox v. Davis, 260 F.3d 1009, 1012-13 (9th Cir. 2001) (for § 1983 claims, federal courts apply the forum state’s personal injury statute of limitations and federal law for determining accrual).

Section 4.16.080(2) provides a three-year limitations period for personal-injury actions.

Nina Martin, App./cross-resp. v. General Construction Company, Resp./cross-app. · filed 2013-10-14(2)

The Martins also challenge the dismissal of their claims against FCCNA based upon the three-year statute of limitations for personal injury actions, RCW 4.16.080(2). ... Thus, the amendment does not relate back to the original pleading, and the statute of limitations bars the Martins' claims against FCCNA.

Subsection (2) imposes a three-year limitations period on personal injury actions, including the limitations period borrowed for this § 1983 action.

Calvin v. Elfo · filed 2015-02-26(2)

The district court properly dismissed Calvin’s action as time-barred because Calvin filed his complaint more than three-year after his release from jail. See Wash. Rev. Code § 4.16.080(2) (three-year statute of limitations for personal injury actions); Douglas v. Noelle, 567 F.3d 1103, 1109 (9th Cir. 2009) (“State law governs the statute of limitations period for § 1983 suits and closely related questions of tolling.”); see also Wash. Rev. Code § 4.16.190(1) (statute of limitations is tolled while a person is “imprisoned on a criminal charge prior to sentencing”); S.J. v. Issaquah Sch. Dist. No. 411, 470 F.3d 1288, 1293 (9th Cir. 2006) (Fed. R. Civ. P. 3 “governs the commencement of federal causes of action using borrowed state statutes of limitations. . . . [T]here is no gap to fill and no basis for resorting to state law to determine when the action is commenced.”).

Subsection (2) provides a three-year limitations period for personal injury actions, which applies to § 1983 claims in Washington as the forum state's personal-injury limitations period.

Johnson v. Di Vittorio · filed 2015-05-26(2)

To the extent Johnson alleged a separate § 1983 claim against Stanhope, the district court properly granted summary judgment because the claim was time-barred. See Wash. Rev. Code § 4.16.080(2) (three-year statute of limitations for personal injury actions); Knox v. Davis, 260 F.3d 1009, 1012-13 (9th Cir. 2001) (for § 1983 claims, federal courts apply the forum state’s personal injury statute of limitations and apply federal law to determine accrual; a § 1983 claim accrues when the plaintiff knows or has reason to know of the injury that forms the basis of the action).

Section 4.16.080(2) requires WLAD discrimination claims to be brought within three years because the WLAD has no separate limitations period.

Knutson v. Wenatchee School District · filed 2015-07-21(2)

The WLAD does not contain its own limitations period. Discrimination claims must be brought within three years under the general three-year statute of limitations for personal injury actions. RCW 4.16.080(2); Antonius, 153 Wn.2d at 261-62.

Section 4.16.080(2) requires WLAD discrimination and retaliation claims to be filed within three years after accrual.

Demmings v. Pacific Maritime Association · filed 2016-03-25(2)

The district court properly dismissed as time-barred Demmings’s claims that he was discriminated and retaliated against in violation of the WLAD because Demmings failed to file this action within three years of when his claims accrued, which was when Demmings was deregistered in September 2008. See Wash. Rev. Code § 4.16.080(2); Cox v. Oasis Physical Therapy, PLLC, 222 P.3d 119, 128-29 (Wash. Ct. App. 2009) (explaining that “[d]iscrimination claims must be brought within three years under the general three-year statute of limitations for personal injury actions” and that “where a discrete act of discrimination is alleged, the limitations period runs from the act” (citation and internal quotation marks omitted)).

Section 4.16.080(2) imposes a three-year limitations period on actions for taking, detaining, or injuring personal property, including specific recovery, and subsection (4) imposes a three-year period for fraud.

Azpitarte v. Biscay · filed 2016-06-27(2), (4)

It is undisputed that the statute of limitations for conversion, replevin, and fraud/misrepresentation claims is three years. RCW 4.16.080(2) (for "[a]n action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof. . . ."); RCW 4.16.080(4) (fraud). It is undisputed that Azpitarte filed his suit roughly seven years after Biscay purchased the truck, and four years after Burnett bought it from Biscay. Thus, if the limitations period commenced on or around these dates of sale, then Azpitarte's action was filed beyond the three-year statute of limitations.

Section 4.16.080 provides a three-year limitations period for personal injury actions, which the court applied to Denham’s § 1983 action.

Robert Denham, Jr. v. Cease · filed 2016-11-03

The district court properly dismissed Denham’s action as barred by the applicable three-year statute of limitations.

Section 4.16.080 imposes a three-year limitations period on personal injury claims.

Fager v. Olympic Peninsula Narcotics Enforcement Team · filed 2017-06-21

The district court correctly concluded that the Plaintiffs-Appellants’ Fourth Amendment, due process, and wrongful discharge claims were barred by Washington’s three-year statute of limitations for personal injury claims.

Section 4.16.080(2) provides a three-year statute of limitations for personal injury torts in Washington.

A.T. v. Everett Sch. Dist. · filed 2018-01-09(2)

In Washington, personal injury torts have a three-year statute of limitations period. Joshua v. Newell , 871 F.2d 884, 886 (9th Cir. 1989) ; RCW 4.16.080(2).

Subsection (2) provides a three-year limitations period for personal injury actions, which applies to WLAD claims.

Harouna Fall v. Delta Air Lines · filed 2018-07-18(2)

Washington’s general three-year statute of limitations for personal injury actions applies to WLAD claims.

Section 4.16.080(2) provides a three-year limitations period for WLAD claims because they are personal injury actions.

Hoover v. Pam Badger · filed 2018-09-24(2)

WLAD claims are subject to the general three-year statute of limitations for personal injury actions. Antonius, 153 Wn.2d at 261-62 (citing RCW 4.16.080(2)).

Subsection (2) provides a three-year limitations period for personal-injury actions, which applies to § 1983 claims in Washington.

A H v. Hellyer · filed 2020-05-01(2)

Section 1983 does not have its own statute of limitations, so “[f]ederal courts in § 1983 actions apply the state statute of limitations from personal-injury claims and borrow the state’s tolling rules.” ... In Washington, Section 1983 claims are subject to the three-year statute of limitations for personal injury actions. Bagley v. CMC Real Estate Corp., 923 F.2d 758, 760 (9th Cir. 1991); see RCW 4.16.080(2). ... Here, Plaintiff’s Section 1983 claim concerns an assault that is alleged to have occurred on December 19, 2016. ... If Plaintiff’s claim is measured by the date of the alleged assault, the statute of limitations ran on December 19, 2019. ... Because Plaintiff’s Section 1983 claim is untimely, Defendants’ Motion to Dismiss succeeds on the merits.

Section 4.16.080(2) provides a three-year statute of limitations for personal injury actions, which applies to section 1983 claims in Washington.

Hanrahan v. King County · filed 2021-01-08(2)

In Washington State, the statute of limitations for personal injury actions is three years. RCW 4.16.080(2). A court must dismiss a claim if the statute of limitations bars it. Huynh v. Chase Manhattan Bank, 465 F.3d 992, 997 (9th Cir. 2006). Hanrahan’s assault occurred on August 16, 2016. Accordingly, the three-year statute of limitations ran on August 16, 2019. Because Hanrahan did not file his lawsuit until October 18, 2019, the statute of limitations bars his constitutional claims.

Section 4.16.080(2) imposes a three-year limitations period on personal injury actions.

Judd v. Nevin · filed 2021-05-04(2)

In Washington, the statute of limitations for personal injury actions is three years, see RCW 4.16.080(2), and this three-year period therefore applies to Mr. Judd’s § 1983 claims.

Section 4.16.080(2) supplies a three-year limitations period for personal-injury actions, including § 1983 claims that borrow Washington’s limitations period.

Palmer v. King County · filed 2021-05-05(2)

Claims brought under 42 U.S.C. § 1983 borrow the forum state’s statute of limitations for personal injury claims, and the Ninth Circuit has identified RCW 4.16.080(2) as providing the relevant limitations period. ... RCW 4.16.080(2) provides that personal injury actions must be commenced within three years.

Section 4.16.080(2) requires personal-injury and tort actions, including the § 1983 and negligence claims discussed here, to be brought within three years.

Koppenstein v. State of Washington · filed 2021-07-08(2)

Claims brought pursuant to 42 U.S.C. §1983 are governed by the statute of limitations of the local jurisdiction for personal injury actions. ... In Washington, personal injury actions must be brought within three years. RCW § 4.16.080(2). Accordingly, the statute of limitations applicable to Plaintiff’s §1983 claims is three years. ... Tort actions, like Plaintiff’s claim for negligence must be brought within three years under RCW § 4.16.080(2).

Section 4.16.080(2) provides a three-year statute of limitations for personal injury actions in Washington.

Carter v. Durkan · filed 2021-12-22(2)

In Washington State, the statute of limitations for personal injury actions is three years, see RCW 4.16.080(2), and this three-year period therefore applies to each of Mr. Carter’s § 1983 claims.

Section 4.16.080(2) provides a three-year limitations period for personal-injury tort claims.

Nguyen v. City of Vancouver · filed 2022-06-08(2)

Because Washington is the forum state, the Court applies Washington’s three-year limitations period for personal injury torts under RCW 4.16.080(2).

Section 4.16.080(2) provides a three-year limitations period for Washington personal-injury lawsuits, including § 1983 claims brought in federal court.

Boyd v. Constantine · filed 2022-06-14(2)

Federal courts apply the forum state’s personal injury statute of limitations to § 1983 claims. ... Personal injury lawsuits in Washington, with a few exceptions that are not applicable here, are governed by a three-year statute of limitations. RCW 4.16.080(2).

Subsection (2) provides a three-year limitations period for personal injury actions, which Washington uses for § 1983 claims.

Ellis v. State of Arizona · filed 2022-10-26(2)

In Washington, the statute of limitations for personal injury actions—and therefore for Section 1983 claims—is three years. See RCW 4.16.080(2).

Section 4.16.080(2) imposes a three-year statute of limitations on personal-injury claims, which the court applied to § 1983 and § 1985 claims.

Dang v. Johnson · filed 2023-06-21(2)

Under Washington law, personal injury claims are limited by a statute of limitations of three years. RCW 4.16.080(2). Section 1985 claims are governed by the same statute of limitations as § 1983 claims.

Section 4.16.080(2) imposes a three-year limitation period on actions for taking, detaining, or injuring personal property and other unenumerated injuries.

Chris Walters, V. Reynolds · filed 2023-06-26(2)

Applicable here, RCW 4.16.080(2) provides that “[a]n action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof, or for any other injury to the person or rights of another not hereinafter enumerated” is subject to a three-year statute of limitations.

Section 4.16.080(2) supplies a three-year limitations period for personal-injury claims, including borrowed limitations periods for § 1983 claims.

McGary v. Inslee · filed 2023-09-08(2)

Section 1983 contains no limitations period. Courts instead “borrow” § 1983 limitations periods from analogous state law. Specifically, they borrow the state’s “general or residual statute for personal injury actions.” Owens v. Okure, 488 U.S. 235, 250 (1989). In Washington, that statute is RCW 4.16.080(2), which is a three-year limitations period. Bagley v. CMC Real Est. Corp., 923 F.2d 758, 760 (9th Cir. 1991). Therefore, in this District, the limitations period for a § 1983 claim is three years.

Subsection (2) provides a three-year limitations period for personal-injury actions, which Washington applies to § 1983 claims.

Gossett v. Gailfus · filed 2023-12-04(2)

In Washington, the statute of limitations for personal injury actions—and thus for § 1983 claims—is three years. See RCW 4.16.080(2).

Section 4.16.080(2) imposes a three-year limitations period on personal-injury claims, including negligence and negligent infliction of emotional distress and, absent a specific period, WLAD claims.

Parker v. Society for Creative Anachronism Inc · filed 2024-03-11(2)

The statute of limitations for a Washington Law Against Discrimination (“WLAD”) hostile work environment claim is three years. Antonius v. King Cnty., 153 Wn.2d 256, 261-62 (2004)(noting that the WLAD does not contain its own limitations period; accordingly, WLAD claims must be brought within three years under the general three-year statute of limitations for personal injury actions, RCW 4.16.080(2)). Likewise, claims for negligence and negligent infliction of emotional distress must be brought within three years. RCW 4.16.080(2). ... The Plaintiffs filed this case on January 25, 2023. Dkt. 1. Any claims based on events which occurred before January 25, 2020 are barred by the applicable statute of limitations.

Subsection (2) provides a three-year limitations period for personal injury actions.

Zarate v. Effland · filed 2024-04-23(2)

As such, a Section 1983 claim must commence within the statute of limitations for personal injury actions in the state where the cause of action arose. Wallace v. Kato, 549 U.S. 384, 387 (2007). In Washington, a personal injury action expires at three years. RCW § 4.16.080(2); see also Bagley v. CMC Real Est. Corp., 923 F.2d 758, 760 (9th Cir. 1991).

Section 4.16.080(2) was treated as supplying a three-year limitations period for personal-injury and intentional-infliction-of-emotional-distress claims.

Brooks Jr v. Ballard · filed 2024-05-30(2)

Other state law claims, including intentional infliction of emotional distress, are subject to a three-year statute of limitations. See Kloepfel v. Bokor, 149 Wash.2d 192, 193 n. 1 (2003). (“’Outrage’ and ‘intentional infliction of emotional distress’ are synonyms for the same tort.”); Cox v. Oasis Physical Therapy, PLLC, 153 Wash. App. 176, 192, 222 P.3d 119, 127 (2009) (applying three-year statute of limitations from RCW 4.16.080(2) to intentional infliction of emotional distress claim). ... However, Plaintiff’s state law tort claims regarding the incidents that took place prior to February 2021 for the claims subjects to the three-year limit, and prior to February 2022 for the claims subject to the two-year limit, are barred by the statute of limitations.

Section 4.16.080(2) requires actions for injury to a person or rights of another not otherwise enumerated to be commenced within three years, and the limitation period for a negligent-investigation claim accrues when the finite investigation ends.

Russell Carter, V. Multicare Health System · filed 2024-07-30(2)

Under RCW 4.16.080, “[a]n action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof, or for any other injury to the person or rights of another not hereinafter enumerated” shall be commenced within three years. RCW 4.16.080(2). ... Because the continuing tort doctrine has not been applied beyond claims regarding damages to real property and it has not been applied to negligent investigations, which have concrete end dates, the statute of limitations for the negligent investigations accrued, at the latest, on May 30, 2018 and expired three years later, on May 30, 2021. ... Accordingly, the trial court did not err in granting the Department’s motion for summary judgment on statute of limitations grounds.

Section 4.16.080(2) supplies Washington’s three-year personal-injury limitations period for WLAD claims, as the analogous state period for ADA and Rehabilitation Act claims, and for § 1983 claims.

Johnson v. Monts · filed 2024-09-16(2)

Here, the Washington law most analogous to each statute is the Washington Law Against Discrimination (WLAD), for which courts apply Washington’s three-year statute of limitations period for personal injury actions under RCW 4.16.080(2). ... Washington’s three-year limitations period for personal injury actions also applies to claims under Section 1983. RCW 4.16.080(2); see Bird v. Dep’t of Hum. Servs., 935 F.3d 738, 743 (9th Cir. 2019) (holding the relevant statute of limitations for claims brought under Section 1983 is the forum state’s statute of limitations for personal injury actions).

Section 4.16.080(2) imposes a three-year statute of limitations on personal-injury claims.

Lyon v. Thurston County · filed 2025-01-16(2)

In Washington State, the statute of limitations for a personal injury claim is three years. RCW 4.16.080(2).

Section 4.16.080(2) sets a three-year limitations period for Washington personal injury actions, which applies to § 1983 claims through Washington’s borrowed limitations period.

Bigelow · filed 2025-11-14(2)

Claims brought pursuant to 42 U.S.C. § 1983 are governed by the statute of limitations of the local jurisdiction for personal injury actions. ... In Washington, personal injury actions must be brought within three years. RCW § 4.16.080(2). Accordingly, the statute of limitations applicable to plaintiff's § 1983 claims is three years.

Section 4.16.080 provides a three-year limitations period for Washington personal-injury tort claims, which the court applied to § 1983 claims.

Carby · filed 2025-12-16

First, section 1983 claims “looks to the law of the State in which the cause of action arose” to determine the statute of limitations length. Wallace v. Kato, 549 U.S. 384, 387 (2007). Specifically, the state’s statute of limitations for personal injury torts. Id. (citations omitted). Washington’s personal injury tort statute of limitations is within three years. RCW 4.16.080. Additionally, for false arrests, it “begins to run at the time the claimant becomes detained pursuant to legal process.” Wallace, 549 U.S. at 397. Plaintiff alleges illegal detainment occurred on August 20, 2022, and November 6, 2021. ECF No. 1 at 5. The August 20, 2022, allegation statute of limitations expired on August 20, 2025. Plaintiff filed this claim on August 19, 2025. Therefore, this particular allegation is not barred by the statute of limitations. However, Plaintiff’s November 6, 2021, claim is barred because the statute of limitations for that claim expired on November 6, 2024.

Section 4.16.080(2) provides a three-year limitations period for personal injury actions, which applies to § 1983 claims because their limitations period is borrowed from state personal-injury law.

Sherman v. Hobbs · filed 2020-07-21(2)

The Court notes that, even if not barred by Heck, Plaintiff’s claims are time-barred as § 1983 claims must be brought within three years. See, Wilson v. Garcia, 471 U.S. 261, 279-80, 105 S.Ct. 1938, 85 L.Ed.2d 254 (1985) (limitations period for § 1983 claims is determined by state statute of limitations for personal injury actions); Wash.Rev.Code § 4.16.080(2) (setting at three years the statute of limitations for personal injury actions).

Section 4.16.080(2) provides a three-year statute of limitations for personal injury actions, barring claims arising from events more than three years before suit.

Gossage v. Washington · filed 2005-12-13(2)

The district court properly granted summary judgment on Gossage’s claims arising from events that occurred before March 13, 2000, because they were time-barred. See Wash. Rev.Code § 4.16.080(2) (providing a three-year statute of limitations for personal injury actions).

Subsection (5)'s three-year limitation for actions against a coroner for official acts or omissions does not apply to a non-liability judicial-review action under RCW 68.50.015.

Thompson v. Wilson · filed 2008-01-23(5)

Because RCW 68.50.015 does not contemplate an action resulting in liability, RCW 4.16.080(5), by its plain language, does not apply. Thus, the three-year limitation period cited in RCW 4.16.080(5) is likewise inapplicable.

Section 4.16.080(1) imposes a three-year limitations period on waste or trespass on real property.

Trotzer v. Vig · filed 2009-01-13(1)

Because, as the trial court correctly ruled, the applicable statute of limitations is three years, it barred Trotzer’s action on the 2000 trespass because he commenced it in November 2003,8 more than three years after the Vigs’ spring 2000 trespass. ... The statute of limitations for breach of a written contract is six years. RCW 4.16.040(1). The statute of limitations for waste or trespass on real property is three years. RCW 4.16.080(1).

Section 4.16.080(1) gives a three-year limitations period for waste or trespass on real property.

Trotzer v. Vig · filed 2009-03-24(1)

The statute of limitations for waste or trespass on real property is three years. RCW 4.16.080(1).

Section 4.16.080(1) provides a three-year limitations period for actions for waste or trespass upon real property, but it does not apply to nuisance actions.

3Pak LLC v. City of Seattle · filed 2024-01-17(1)

RCW 4.16.080(1) creates a three-year statute of limitations for “action[s] for waste or trespass upon real property,” but it does not mention nuisance.

Subsection (3) imposes a three-year limitations period for legal-malpractice claims, subject to the discovery rule.

Velocity Capital Partners App. v. Lasher Holzapfel Sperry & Ebberson · filed 2015-08-03(3)

The three-year limitations period expired before Velocity commenced this suit in December 2012.

Section 4.16.080 gives tort claims, including bad-faith claims, a three-year limitations period.

Moratti Ex Rel. Tarutis v. Farmers Ins. Co. · filed 2011-07-05

There is a three-year statute of limitations for tort claims.

A bad-faith insurance claim accrues for limitations purposes when the final judgment in the underlying action is entered.

Moratti v. Farmers Insurance · filed 2011-07-05

The action “accrues for purposes of the statute of limitation when the final judgment is entered.”

Subsection (3) imposes a three-year limitations period on an equitable committed-intimate-relationship claim, running from the end of the relationship.

In re Kelly · filed 2012-09-18(3)

The three-year statute of limitations applies to actions “upon a contract or liability, express or implied, which is not in writing, and does not arise out of any written instrument.” RCW 4.16.080(3). ... We conclude that the equitable doctrine of CIR is subject to a three-year statute of limitations. A party must sue to establish that the relationship existed within three years of the end of the relationship.

Subsection (3) imposes a three-year limitations period on a property-distribution claim based on a committed intimate relationship, running from the parties’ separation and the end of the marital community.

Mcbeth v. Ruby E. Ketschau · filed 2019-09-17(3)

We hold that when parties to a committed intimate relationship marry, the statute of limitations for a property distribution claim based on the committed intimate relationship doctrine begins to run on the date the parties separate and the marital community ends.