Wash. Rev. Code § 4.16.080

For an ordinary personal-injury action, the three-year limitations period generally accrues when the act or omission causes the injury, unless the plaintiff could not have immediately known of the injury's cause.

Steven W. Hyde, Et Ux. v. City Of Lake Stevens · filed 2014-01-21(2)

When a pjaintiff brings suit for injury caused by negligent use of a weapon and he fails! to show that he could not have immediately discovered that this was a possible cause of his injury, the statute of limitations began to run from the date of injury. ... While Hyde did not in fact discover at the time of the injury that a possible cause of the injury was misuse of the taser, he fails to show that he could not have made that inquiry at the time. Accordingly, as an ordinary personal injury claim, the general rule is that a cause of action accrues at the time the act or omission occurs.15 In this case , this was when the tasing and resulting injury occurred, on June 11, 2009.

Section 4.16.080(2) imposes a three-year limitations period for actions for injury to the person.

James v. Washington State Patrol · filed 2025-08-05(2)

In Washington, the statute of limitations for “injury to the person” is three years. RCW 4.16.080(2); see Dunn v. City of Seattle, 420 F. Supp. 3d 1148, 1156–57 (W.D. Wash. 2019) (finding that RCW 4.16.080(2) prescribed a three-year statute of limitations in Section 1983 claim). Here, given that the complained-of conduct occurred nearly 10 years ago, Plaintiff is time-barred from basing a Section 1983 claim upon it.

Section 4.16.080(2) imposes a three-year limitations period on a § 1983 action, running when the plaintiff had reason to know of the injury, subject to any established basis for equitable tolling.

Young v. Lehman · filed 2007-09-27(2)

The district court properly determined that Young’s section 1983 action was barred by Washington’s three-year statute of limitations, see Wash. Rev.Code § 4.16.080(2); Bagley v. CMC Real Estate Corp., 923 F.2d 758, 760 (9th Cir.1991), because Young had reason to know of his injury over three years prior to filing his action, see id. at 760-61, and because he failed to establish a basis for equitable tolling, see Millay v. Cam, 135 Wash.2d 193, 955 P.2d 791, 797 (1998) (“The predicates for equitable tolling are bad faith, deception, or false assurances by the de*522fendant and the exercise of diligence by the plaintiff.”).

Section 4.16.080(4) imposes a three-year limitations period on claims such as aiding and abetting fraud, and the discovery rule starts that period when the claimant knew or should have known the facts giving rise to the claim and sustained actual damage.

John Norton And Kristine Norton, Apps. v. Graham & Dunn, P.c., Res. · filed 2016-04-18(4)

Norton does not dispute and we agree the three-year statute of limitations applies to these claims against Graham & Dunn. See RCW 21.20.430(4)(b) (securities fraud); RCW 4.16.080(4) (aiding and abetting fraud). ... The discovery rule operates to prevent the commencement of the running of the statutory period until the time the claimant knows or should have known the facts giving rise to his claim. ... The discovery rule delays the start of the statute of limitations period "only until the time when a plaintiff, through the exercise of due diligence, should have discovered the basis for the cause of action." ... Here, the statute of limitations began when Norton discovered or should have discovered through the exercise of due diligence the facts of the fraud or securities fraud and sustained actual damage as a result.

Section 4.16.080(3) gives a resulting-trust action a three-year limitations period that begins when the trustee repudiates the trust and the beneficiary receives notice.

Vince Badkin, V Badkin · filed 2017-06-13(3)

An action based on a resulting trust is subject to a three-year statute of limitations. Arneman v. Arneman, 43 Wn.2d 787, 797, 264 P.2d 256 (1953); RCW 4.16.080(3), (4). The statute of limitations begins to run on a resulting trust not when the trust is formed, but “when the trustee repudiates the trust and notice of such repudiation is brought home to the beneficiary.”

Section 4.16.080(4) requires fraud and fraudulent-inducement actions to be commenced within three years, subject to the discovery rule delaying accrual until the plaintiff discovers or reasonably should discover the injury and its likely wrongful cause.

Putzier v. Ace Hardware Corp. · filed 2014-06-25(4)

Under Washington law, Putzier and Hometown Aee must have commenced their fraud and fraudulent inducement actions within three years of the alleged fraud. ... The discovery rule tolls the statute of limitations for fraud until a plaintiff discovers or reasonably should have discovered that he has been injured and that his injury was likely caused by the wrongful acts of another.

RCW 4.16.080's three-year limitations period applies to claims for invasion of privacy by publication.

Dezmond Emeson, V Dept. Of Corrections · filed 2016-05-03

Consequently, Eastwood’s analysis and holding are inapplicable, and we hold that the three-year statute of limitations applies to the claim of invasion of privacy by publication.

Section 4.16.080 imposes a three-year statute of limitations on a claim under the Washington Privacy Act.

Karen Konz, V. Hofmann · filed 2025-01-21

The statute of limitations to bring a claim under the Washington privacy act is three years. RCW 4.16.080. ... Because Konz cannot raise this issue for the first time on appeal and the statute of limitations has run, we need not address the issue.

Section 4.16.080(2) provides a three-year limitations period for an action seeking recovery for any other injury to the person or rights of another, but it does not apply to the State’s RCW 19.86.080 action because RCW 4.16.160 exempts that action from the general statutes of limitations.

State v. LG Electronics, Inc. · filed 2016-07-14(2)

LG Electronics ask us to find that the State’s .080 parens patriae claim for injunctive relief and restitution is barred by RCW 19.86.120, the CPA’s statute of limitations for .090 damages claims. Alternatively, they contend that one of the general statutes of limitations in chapter 4.16 RCW applies: the catchall three-year statute of limitations for actions seeking recovery for “any other injury to the person or rights of another,” RCW 4.16.080(2), or the even broader catchall two-year limitations period for “[a]n action for relief not hereinbefore provided,” RCW 4.16.130. Suppl. Br. of Pet’rs at 13-14. We find that by its plain language, RCW 19.86.120 does not apply to .080 claims. We also find that the State’s action is not subject to the general statutes of limitation because RCW 4.16.160, which codifies the common law nullum tempus3 doctrine, applies.

Section 4.16.080(2)'s three-year limitations period applies when Washington substantive law governs the claim.

Woodward v. Taylor · filed 2016-01-14(2)

Because Washington’s substantive law applies, the plaintiff’s case is not time barred.

Section 4.16.080(2) is a three-year catchall limitation for injuries not otherwise enumerated, so it does not govern wrongful-death claims arising from negligent health care when RCW 4.16.350(3) specifically applies.

Fast v. Kennewick Pub. Hosp. Dist. · filed 2016-11-17(2)

The very language of RCW 4.16.080(2) ("not hereinafter enumerated") confirms that the general torts catchall statute of limitations does not apply to cases based on medical negligence, which are enumerated in RCW 4.16.350. Accordingly, we hold that in cases of wrongful death resulting from negligent health care, the medical negligence statute of limitations (MNSOL) (RCW 4.16.350(3)) applies.

Section 4.16.080(2) sets a three-year limitations period for injuries to a person or another’s rights not covered by a more specific limitations statute.

Fast v. Kennewick Public Hospital District · filed 2016-11-17(2)

In cases of medical negligence, the language of RCW 4.16.080(2), which provides that it is limited to actions “not hereinafter enumerated,” requires application of the more specific MNSOL in RCW 4.16.350(3).

Section 4.16.080(2) imposes a three-year limitations period on tort claims, running under Washington’s discovery rule when the claimant discovers or should discover the claim’s elements.

Piche v. Safeco Insurance Company of America · filed 2025-02-04(2)

The Pichés’ negligence, bad faith, and IFCA claims are subject to Washington’s general, three-year statute of limitations for tort actions. See Safeco Ins. Co. of Am. v. Butler, 823 P.2d 499 (1992); RCW 4.16.080. ... Under Washington’s “discovery rule of accrual,” a cause of action “accrues when the plaintiff discovers, or in the reasonable exercise of diligence should discover, the elements of the cause of action.” ... Thus, the Pichés’ extracontractual claims accrued on August 29, 2022. The Pichés filed this lawsuit on July 17, 2023, so their extracontractual claims easily fall within the statute of limitations.

The three-year limitations period in subsection (2) begins when the cause of action accrues, and for recurring condominium assessments a new claim accrues each time an assessment causing actual damage is paid.

Shamim Mohandessi And Joseph Grace, Apps/cross-res. v. Urban Venture, Llc, Res/cross-apps. · filed 2020-03-09(2)

ROW 4.16.080(2) states that “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. ... Here, the plaintiffs suffer actual and appreciable damage when they pay an assessment that violates RCW 64.34.224(1). ... Thus, each time the MA board passes a budget, the RA members suffer actual and appreciable damage and a new cause of action accrues for violations of RCW 64.34.224(1) and RCW 64.34.090.

Section 4.16.080 establishes limitation periods for certain categories of claims but does not itself create a cause of action.

Daisy A. Amo v. Harborview Medical Center, Et Ano · filed 2020-04-20

And the provision she cites, RCW 4.16.080, establishes the limitations period for certain categories of claims, but does not create any cause of action.

Section 4.16.080(2) gives claims for intentional infliction of emotional distress a three-year statute of limitations.

Minnie Thomas & Lawrence Williams, Apps V. Redmond Police Dept., Resp · filed 2021-11-08(2)

The statute of limitations for intentional infliction of emotional distress is also three years. RCW 4.16.080(2).

Section 4.16.080(2) makes a proposed civil-conspiracy claim futile when the statute of limitations on that claim has already expired.

Zhi H. Feng, V. Jen Turner · filed 2023-11-06(2)

Negotiating the terms of a rental contract is perfectly legal. Even if it were not, or if the defendants utilized unlawful means during the negotiation (which Feng does not allege), the statute of limitations on this claim expired many years ago. See RCW 4.16.080(2). Because Feng does not allege facts that would support a timely claim for civil conspiracy, his proposed amendment would have been futile.

Section 4.16.080(4) imposes a three-year limitations period for fraud actions, accruing when the aggrieved party discovers the facts constituting the fraud.

Harvey v. Mid-Century Insurance Company · filed 2024-05-13(4)

Under Washington law, claims for negligence, fraud, insurance bad faith, and for violations of IFCA are subject to a three-year statute of limitations. See Wash. Rev. Code 4.16.080(2) (negligence); Wash. Rev. Code § 4.16.080(4) (fraud); Moratti v. Farmers Ins. Co. of Wash., 254 P.3d 939, 942 (Wash. Ct. App. 2011) (insurance bad faith); Trumball v. Am. Sec. Ins. Co., No. C17-00125-RAJ, 2018 WL 3769797, at *2 (W.D. Wash. Aug. 9, 2018) (IFCA). ... And finally, a fraud action accrues when the aggrieved party discovers “the facts constituting the fraud[.]” Wash. Rev. Code § 4.16.080(4); see also Shepard v. Holmes, 345 P.3d 786, 790 (Wash. Ct. App. 2014). ... Farmers has shown that there is no genuine dispute of material fact regarding its contention that the statute of limitations expired for Plaintiffs’ negligence, fraud, insurance bad faith, and IFCA claims in April 2022,3 and for Plaintiffs’ CPA claim in April 2023. Because Plaintiffs did not sue until May 5, 2023, Dkt. No. 1-2 at 2, Farmers is entitled to judgment as a matter of law on those claims.

Section 4.16.080(4) gives fraud claims a three-year limitations period that accrues when the aggrieved party discovers the facts constituting the fraud.

Kurt Benshoof, V. Owen · filed 2024-08-26(4)

The statute of limitations for fraud is three years, and “the cause of action in such case [is] not to be deemed to have accrued until the discovery by the aggrieved party of the facts constituting the fraud.” RCW 4.16.080(4). The limitations period is also three years for an action “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), or for an action “for any other injury to . . . the rights of another not hereinafter enumerated,” RCW 4.16.080(2), and there is a catch-all limitation period of two years from accrual for an action “for relief not hereinbefore provided for,” RCW 4.16.130. The trial court properly dismissed Benshoof’s constructive fraud claim because it was time barred. Benshoof alleged in his complaint that Owen repudiated any agreement by at least 2018, and he did not file suit until March 2022, more than three years after the alleged repudiation. The limitation period had expired. The trial court did not err in dismissing Benshoof’s constructive fraud claim.

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

Brown v. Horizon Air · filed 2024-11-01(2)

The statute of limitations for a negligence claim in Washington is three years. RCW 4.16.080(2).

Section 4.16.080 provides a three-year limitations period for the listed tort claims; the period runs from accrual, while fraud runs from when the plaintiff discovers or reasonably should discover the constituting facts.

Arabpour v. The Plan Administrator · filed 2025-09-19(2), (3), and (4)

For each of these causes of action, Washington sets the statute of limitations at three years. Appellants’ Claims, based on alleged damages arising from the suspension of their accounts in October 2017, accrued long before May 8, 2020 (i.e., three years before the May 8, 2023 Petition Date). Any of the following claims arising before May 8, 2020 are thus time-barred: (1) negligence or negligent misrepresentation, (2) conversion, (3) fraud, (4) breach of fiduciary duty, (5) unjust enrichment, (6) personal injury and negligent or intentional emotional distress, (7) breach of implied covenant of good faith and fair dealing, and (8) civil conspiracy. ... First, any claim for negligence or negligent misrepresentation expires after a three-year limitations period, which begins to run when the plaintiff has the right to seek relief in court. Sabey v. Howard Johnson & Co., 5 P.3d 730, 739 (Wash. Ct. App. 2000) (citing RCW § 4.16.080(2), (4)). Second, any claim for conversion must be brought within three years after the cause of action accrues. Crisman v. Crisman, 931 P.2d 163, 165 (Wash. Ct. App. 1997) (citing RCW § 4.16.080(2)). Third, any claim for fraud has a limitations period of three years. RCW §§ 21.20.430(4)(b), 4.16.080(4); Young v. Savidge, 230 P.3d 222, 230 (Wash. Ct. App. 2010); Ives v. Ramsden, 174 P.3d 1231, 1239 (Wash. Ct. App. 2008). The limitations period starts to run when the aggrieved party discovers, or through reasonable diligence should have discovered, facts constituting the fraud. RCW § 4.16.080(4); Ives, 174 P.3d at 1239. ... Fifth, any claim for unjust enrichment has a limitations period of three years. Davenport v. Wash. Educ. Ass’n, 197 P.3d 686, 704 (Wash. Ct. App. 2008) (citing RCW § 4.16.080(3)).

Section 4.16.080 imposes a three-year statute of limitations on claims for tortious interference and intentional infliction of emotional distress.

Button · filed 2026-01-20

The Court similarly finds the Buttons’ claims for tortious interference and intentional infliction of emotional distress barred by the statute of limitations. Wash. Rev. Code § 4.16.080; City of Seattle v. Blume, 947 P.2d 223, 251 (Wash. 1997) (“[T]he limitations period for a cause of action for tortious interference is three years[.]”); Townsley v. Lifewise Assurance Co., Case No. C15-1228-JCC, 2016 WL 1393548, at *3 (W.D. Wash. April 8, 2016) (Under Washington law, intentional infliction of emotional distress is subject to, at most, a three-year limitations period).

Section 4.16.080(2) gives negligence claims a three-year statute of limitations that begins when the cause of action accrues, typically when the plaintiff suffers injury or damage.

Shauna Soule & Sheldon Soule v. Ferguson · filed 2026-03-19(2)

Claims for negligence are governed by a three-year statute of limitations. RCW 4.16.080(2). A limitation period begins to run when the plaintiff’s cause of action accrues. Malnar v. Carlson, 128 Wn.2d 521, 529, 910 P.2d 455 (1996). A cause of action accrues, and the limitation period begins to run, when the plaintiff has a right to apply to a court for relief, which is typically when the plaintiff suffers injury or damage. In re Ests. of Hibbard, 118 Wn.2d 737, 744, 826 P.2d 690 (1992).

Section 4.16.080 provides a three-year limitations period for IIED claims, but a qualifying domestic-violence course of conduct is timely as a whole when its final act falls within that period.

Sreya Vuth, V. Tavakoli · filed 2026-06-23

IIED claims are subject to a three-year statute of limitations. RCW 4.16.080; Cox, 153 Wn. App. at 192. Generally, this means that the tortious conduct must fall within the three-year statutory period to be timely.

Section 4.16.080(2) imposes a three-year limitations period, requiring the action to be commenced within three years of the relevant event.

Johnson International Co. v. Jackson National Life Insurance · filed 1993-01-27(2)

I am satisfied that the statute of limitations relevant to the negligence theory of recovery had expired by the time plaintiff sought to amend on September 8, 1992, unless the amendment “related back’’ to the original complaint filed on Decembér 14, 1988. ... Judgment as a matter of law will be granted in favor of the defendant and against the plaintiff, and the plaintiff shall take nothing on the negligence theory of recovery (second theory of recovery) for the reason that the statute of limitations bars recovery. ... The parties agree that suit had to be commenced within three years of Warford's death. ... I agree. See Wash.Rev.Code § 4.16.080(2) (1992). This meant suit had to be commenced by August 13, 1989, and suit was filed in this case prior to that date.

Subsection (2) imposes a three-year limitations period, so a claim filed in February 2000 was untimely when the plaintiff knew of the alleged inadequate treatment by January 1993.

Skinner v. Riveland · filed 2002-01-25(2)

The district court properly found that Skinner’s Eighth Amendment claim alleging inadequate mental healthcare was barred by the three-year statute of limitations. See Wash. Rev.Code § 4.16.080(2). Skinner was aware since at least January 1993 that the mental treatment for sexual deviancy available during his incarceration was allegedly inadequate because it was not “Afro-centric.” Thus, Skinner’s claim was untimely filed in February 2000.

Section 4.16.080 bars the claims at issue when the alleged misdiagnosis or forced medication occurred more than three years before the complaint was filed.

Howard v. Lehman · filed 2002-12-12

The district court properly dismissed Howard’s claims against Clark County Jail and Columbia River Mental Health Services and their employees as time-barred because Howard’s complaint alleges only misdiagnoses or forced administration of medications that occurred more than three years before Howard filed his complaint. See Wash. Rev.Code § 4.16.080; RK Ventures, Inc. v. City of Seattle, 307 F.3d 1045, 1058 (9th Cir. 2002).

Section 4.16.080 imposes a three-year limitations period on claims for trespass, negligence, conversion, tortious interference, and nuisance.

Skokomish Indian Tribe v. United States · filed 2003-06-03

The applicable state statutes of limitation for these claims are (1) ten years for inverse condemnation, Highline Sch. Distr. v. Port of Seattle, 87 Wash.2d 6, 548 P.2d 1085, 1089 (1976); and (2) three years for trespass, negligence, conversion, tortious interference, and nuisance, Wash. Rev.Code § 4.16.080. ... We agree with the district court that the Tribe's aggradation-related claims accrued at least by February 16, 1989 when Busch wrote the above letter, and that summary judgment was therefore proper. The Tribe filed its complaint on November 19, 1999, more than ten years after its aggradation-related claims accrued. Thus, the aggradation-related claims are barred by the statute of limitations.

Section 4.16.080 sets a three-year statute of limitations for trespass, negligence, conversion, tortious interference, nuisance, and actions under RCW 4.24.630.

Indian v. Tacoma Public Utilities · filed 2005-03-08

The statutes of limitations for trespass, negligence, conversion, tortious interference, nuisance and actions under Washington Revised Code section 4.24.630 are three years.

Section 4.16.080 imposes a three-year limitations period, making an action untimely when filed more than three years after the alleged events.

Blatt v. Deede · filed 2005-06-22

The district court properly concluded that Blatt’s current action was untimely pursuant to Wash. Rev.Code § 4.16.080 because the action was filed more than three years after the alleged events.

Subsection (2) supplies a three-year statute of limitations for claims within its scope.

Gotcher v. Kamalu · filed 2005-06-22(2)

The district court did not err when it dismissed the claims against King County Jail with prejudice, because Gotcher failed to state a claim against the Jail within the three-year statute of limitations. See Wash. Rev. Code § 4.16.080(2) (setting forth statute of limitations); see also Cline v. Brusett, 661 F.2d 108, 110 (9th Cir.1981).

Subsection (2) supplies a three-year limitations period for federal claims that borrow Washington’s statute of limitations.

Kelley v. Lake Forest Park City · filed 2005-07-15(2)

The district court properly determined that Kelley’s federal claims were barred by the three-year statute of limitations. See Wash. Rev.Code § 4.16.080(2); RK Ventures, Inc., 307 F.3d at 1058 (applying state statute of limitations to claims brought under sections 1983 and 1985).

Section 4.16.080(2) imposes a three-year limitations period that applies to federal civil-rights claims when state law supplies the limitations period.

Galberth v. Washington · filed 2005-08-04(2)

The district court properly determined that appellants’ federal claims, filed more than five years after the state court decision, were barred by a three-year statute of limitations. See Wash. Rev.Code § 4.16.080(2); RK Ventures, Inc., 307 F.3d at 1058 (applying state statute of limitations to claims brought under sections 1983 and 1985).

Section 4.16.080(2) supplies a three-year statute of limitations that bars a § 1983 claim when the claim is brought after that period.

Mariano v. Everett Housing Authority · filed 2006-01-17(2)

The district court properly granted summary judgment in favor of EHA because Mariano’s section 1983 claim was barred by the three-year statute of limitations. See Wash. Rev.Code § 4.16.080(2); RK Ventures, Inc., 307 F.3d at 1058 (applying state statute of limitations to claims brought under section 1983).

RCW 4.16.080 imposes three-year limitation periods on civil-conspiracy, unjust-enrichment, and misrepresentation claims.

Zhu · filed 2026-01-26(2), (3), (4)

That complaint contained a variety of causes of action against the moving defendants, as summarized below (along with the relevant statutes of limitations): ... Misrepresentation 3 years (RCW 4.16.080(4)) ... Unjust Enrichment 3 years (RCW 4.16.080(3)) ... Civil Conspiracy 3 years (RCW 4.16.080(2)) ... Because the complaint adding the moving defendants was filed on November 8, 2025, and the longest limitation period is four years, conducting supporting claims against them must have occurred no later than November 9, 2021.

Section 4.16.080(2) supplies a three-year limitations period for WLAD claims.

Brooks-Joseph v. City of Seattle · filed 2023-10-05(2)

... (3) WLAD requires that ... “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 v. King Cnty., 153 Wn. 2d 256, 261-62 (2004), a statute of limitation that encompasses the totality of plaintiff’s period of employment with defendants, ... the Court will address plaintiff’s claims on the merits.

Section 4.16.080’s three-year period continues to run on a malpractice claim when the absent defendant can be personally served under the long-arm statute.

Summerrise v. Stephens · filed 1969-04-24

If it were the only statute applicable, the present action would have been barred by the 3-year statute of limitations (RCW 4.16.080) a decade ago. ... That reason having been removed in certain classes of cases by the long-arm statute, the tolling provision in such cases is no longer necessary, and the statute of limitations should again be permitted to perform its purpose of expediting litigation.

Section 4.16.080(2) provides a three-year limitations period for WLAD employment discrimination claims because they involve an invasion of legal rights.

Adler v. Manor · filed 2004-12-23(2)

Instead, courts have applied the general three-year statute of limitations in RCW 4.16.080(2) to WLAD claims reasoning that violations of chapter 49.60 RCW amount to an invasion of a person’s legal rights.

Section 4.16.080(2) provides a three-year limitations period for WLAD claims.

Adler v. Manor · filed 2005-01-07(2)

Instead, courts have applied the general three-year statute of limitations in RCW 4.16.080(2) to WLAD claims reasoning that violations of chapter 49.60 RCW amount to an invasion of a person's legal rights.

Section 4.16.080(2)'s three-year limitations period does not apply to a union member's unauthorized-practice-of-law claim arising from the grievance process when that claim is subsumed in a duty of fair representation claim.

Roland Killian & Dennis Bailey v. International Union Of Operating Engineers, Resp · filed 2016-08-22(2)

In so holding, the Imperato court rejected the argument that it should apply the three year statute of limitations in RCW 4.16.080, the six year statute of limitations for breach of a written agreement in RCW 4.16.040, or the two year statute of limitations in RCW 4.16.130. ... We adhere to Imperato. To the extent the appellants' claims are considered DFR claims, they are subject to a six month statute of limitations period.

The court treated § 4.16.080 as providing a two-year defamation deadline and found a claim alleging a statement within that period timely.

Sarah · filed 2026-02-04

Last, Defendants claim that Plaintiff’s defamation action is time-barred under Revised Code of Washington 4.16.080, which provides for a two-year limitations period for most tort actions. But the CTAC alleges that the most recent defamatory statement occurred in 2025, which falls within the two-year limitations period.