**SMALL CLAIMS ANSWER TEMPLATE

State of Washington – District Court, Small Claims Division**

[// GUIDANCE: This template is drafted for use in Washington State small-claims matters governed by Ch. 12.40 RCW. Adapt all bracketed placeholders before filing. Verify all local–court rules, as several counties impose their own formatting and deadline requirements. Because attorney representation is generally prohibited in WA small-claims actions absent court approval, see Wash. Rev. Code § 12.40.040 (2023), confirm that use of counsel—or counsel-prepared pleadings—is permitted in the particular venue.]

TABLE OF CONTENTS

1. Document Header
2. Definitions (Optional)
3. Operative Provisions – Answer to Complaint
4. Affirmative Defenses
5. Counterclaims/Setoffs (Optional)
6. Prayer for Relief
7. Verification
8. Certificate of Service

1. DOCUMENT HEADER

IN THE DISTRICT COURT OF THE STATE OF WASHINGTON
FOR [COUNTY] COUNTY
SMALL CLAIMS DIVISION

[PLAINTIFF NAME], )
Plaintiff, )
) Case No.: [___]
v. )
) DEFENDANT’S ANSWER,
[DEFENDANT NAME], ) AFFIRMATIVE DEFENSES,
Defendant. ) AND (IF APPLICABLE)
) COUNTERCLAIMS/SETOFFS

COMES NOW [Defendant Name] (“Defendant”), and hereby responds to the Small Claims Notice of Claim (the “Complaint”) filed by [Plaintiff Name] (“Plaintiff”) as follows:

2. DEFINITIONS [Optional—delete if unnecessary]

For purposes of this Answer, the following capitalized terms shall have the meanings set forth below:

a. “Claim” means the monetary demand set forth in the Complaint dated [DATE].
b. “Hearing Date” means the trial date presently scheduled for [DATE] or such other date as the Court may set.

3. OPERATIVE PROVISIONS – ANSWER TO COMPLAINT

[// GUIDANCE: If Plaintiff’s Complaint is divided into numbered paragraphs, track that numbering exactly. Where no formal numbering exists, insert a general denial under § 3(A) and then state any specific admissions/denials in § 3(B).]

A. General Denial
Except as expressly admitted herein, Defendant denies each and every allegation contained in the Complaint and demands strict proof thereof.

B. Specific Admissions and Denials
1. Paragraph ☐: Admitted.
2. Paragraph ☐: Denied.
3. Paragraph ☐: Defendant lacks sufficient information to form a belief as to the truth of the allegations and therefore denies the same.

C. Defendant reserves the right to amend or supplement this Answer to assert additional defenses or claims as discovery or investigation warrants, subject to the approval of this Court and applicable rules.

4. AFFIRMATIVE DEFENSES

Without assuming any burden of proof not otherwise imposed by law, Defendant asserts the following affirmative defenses, each of which is pled in the alternative and without waiver of any other defense:

1. Failure to State a Claim.
2. Lack of Jurisdiction and/or Improper Venue if the underlying transaction arose outside [COUNTY] County.
3. Statute of Limitations. The claim is barred in whole or in part by the limitations periods set forth in Wash. Rev. Code §§ 4.16.040 et seq.
4. Payment and Accord & Satisfaction.
5. Setoff and/or Recoupment.
6. Waiver, Estoppel, and/or Laches.
7. Failure of Consideration.
8. Lack of Standing and/or Real Party in Interest.
9. Unclean Hands.
10. Any other matter constituting an avoidance or affirmative defense under CR 8(c) incorporated by reference for small-claims practice.

[// GUIDANCE: Delete, modify, or supplement defenses to match case facts. Under RCW 12.40, the Court may limit or strike boilerplate defenses if they are not supported by specific factual allegations.]

5. COUNTERCLAIMS / SETOFFS [Optional]

[// GUIDANCE: WA small-claims courts allow counterclaims up to the same statutory dollar limit (currently $10,000 for individuals; $5,000 for businesses) per RCW 12.40.010. A counterclaim must arise out of the same transaction or occurrence, or the Court may order transfer to the regular civil docket.]

A. Counterclaim 1 – [Brief Title]
1. Parties & Jurisdiction.
2. Statement of Facts.
3. Damages Sought: $[___] plus allowable costs.

B. Counterclaim 2 – [If Any]
…

Defendant requests that any judgment for Plaintiff be offset in whole or in part by the amount awarded on these counterclaims.

6. PRAYER FOR RELIEF

WHEREFORE, Defendant respectfully prays that this Court enter judgment as follows:

a. That Plaintiff take nothing by way of the Complaint and that the same be dismissed with prejudice;
b. That judgment be entered in favor of Defendant on all affirmative defenses;
c. That Defendant recover on any counterclaim(s) stated herein in an amount to be proven at trial but not to exceed the jurisdictional limit of this Court;
d. That costs in the amount of $[FEE] and statutory interest be assessed against Plaintiff; and
e. For such other and further relief as the Court deems just and equitable.

7. VERIFICATION

[// GUIDANCE: A notarized verification is not mandatory statewide but may be required by local rule. Remove the notary block if not needed.]

I, [Defendant Name], declare under penalty of perjury under the laws of the State of Washington that the foregoing Answer, Affirmative Defenses, and Counterclaims are true and correct to the best of my knowledge and belief.

DATED this ___ day of __________, 20__ at [City], Washington.

_________________________________
[DEFENDANT NAME], Declarant
[Street Address]
[City, State ZIP]
[Telephone] | [Email]

[NOTARY BLOCK, if required]

8. CERTIFICATE OF SERVICE

I certify that on the ___ day of __________, 20__, I caused a true and correct copy of the foregoing Answer, Affirmative Defenses, and Counterclaims to be served upon:

[PLAINTIFF NAME]
[Plaintiff’s Address]

☐ By first-class U.S. mail, postage prepaid
☐ By personal hand-delivery
☐ By electronic means permitted by the Court (specify): __________

_________________________________
[DEFENDANT NAME]

[// GUIDANCE: Review local small-claims instructions for additional filing or service affidavits. Many Washington district courts require the Answer to be filed/served a specific number of court days before the hearing—commonly 5–7. Insert the applicable deadline here: “Pursuant to [LOCAL RULE], this Answer is timely filed ___ court days before the Hearing Date.”]

END OF DOCUMENT