continuing course of treatment rule in Washington

7 Washington opinions name it 2 courts 1980–2024 1 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (1)

Case	Followed	Cited
Bixler v. Bowmangreen washctapp · 1979 · cited in 1 Washington opinions naming this issue, 1994–1994 2 sentences 1994On appeal, the Court of Appeals reversed the trial court, holding that under the continuing-course-of-treatment rule, "we cannot say as a matter of law that her treatment ceases with her last visit.” Bixler v. Bowman, 24 Wn. 1994App. 815, 819 , 604 P.2d 188 *229 (1979).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (7)

Case	Cited	Years
Samuelson v. Freeman green wash · 1969 2 sentences 2013RCW 4.16.350 was enacted in 1971, after the Washington Supreme Court’s decision in Samuelson v. Freeman, 75 Wn.2d 894 , 454 P.2d 406 (1969), which recognized a cause of action for “continuing negligent treatment.” 6 In a case decided after the enactment of the statute, the court explained: [RCW 4.16.350] substantially modified the continuing course of treatment rule formulated in Samuelson .... 2013RCW 4.16.350 was enacted in 1971, after the Washington Supreme Court’s decision in Samuelson v. Freeman, 75 Wn.2d 894 , 454 P.2d 406 (1969), which recognized a cause of action for “continuing negligent treatment.” 6 In a case decided after the enactment of the statute, the court explained: [RCW 4.16.350] substantially modified the continuing course of treatment rule formulated in Samuelson ....	4	1980–2013
Bixler v. Bowman green wash · 1980 2 sentences 1994In Bixler v. Bowman, 94 Wn.2d 146 , 614 P.2d 1290 (1980), we addressed for the first and, to this point, only time the effect that RCW 4.16.350 had on the continuing-course-of-treatment rule. 1994In Bixler v. Bowman, 94 Wn.2d 146 , 614 P.2d 1290 (1980), we addressed for the first and, to this point, only time the effect that RCW 4.16.350 had on the continuing-course-of-treatment rule.	2	1988–1994
Caughell v. Group Health Cooperative of Puget Sound green wash · 1994 1 sentence 2024Dr. Schaffner points out that under the continuing course of treatment rule, “claimants must allege that the last negligent act, not simply the end of treatment itself, occurred within 3 years of filing suit.” Caughell, 124 Wn.2d at 229 .	1	2024–2024
Lindquist v. Mullen red wash · 1954 2 sentences 1994In declaring these principles, we are, of course, departing from the Lindquist [v. Mullen, 45 Wn.2d 675 , 277 P.2d 724 (1954)] rule and also that part of McCoy v. Stevens, 182 Wash. 55 , 44 P.2d 797 (1935), which rejected the continuing-course-of-treatment concept. 1994In declaring these principles, we are, of course, departing from the Lindquist [v. Mullen, 45 Wn.2d 675 , 277 P.2d 724 (1954)] rule and also that part of McCoy v. Stevens, 182 Wash. 55 , 44 P.2d 797 (1935), which rejected the continuing-course-of-treatment concept.	1	1994–1994
Adams v. Allen green washctapp · 1989 1 sentence 1994Adams, 56 Wn.	1	1994–1994
McCoy v. Stevens green wash · 1935 2 sentences 1994In declaring these principles, we are, of course, departing from the Lindquist [v. Mullen, 45 Wn.2d 675 , 277 P.2d 724 (1954)] rule and also that part of McCoy v. Stevens, 182 Wash. 55 , 44 P.2d 797 (1935), which rejected the continuing-course-of-treatment concept. 1994In declaring these principles, we are, of course, departing from the Lindquist [v. Mullen, 45 Wn.2d 675 , 277 P.2d 724 (1954)] rule and also that part of McCoy v. Stevens, 182 Wash. 55 , 44 P.2d 797 (1935), which rejected the continuing-course-of-treatment concept.	1	1994–1994
Ruth v. Dight red wash · 1969 2 sentences 1994The first of these two opinions, Ruth v. Dight, 75 Wn.2d 660 , 453 P.2d 631 (1969), begins with a timeless description of the tension between the peculiar circumstances of medical malpractice and the rigid application of legal rules: There is a saying that what one does not know does not hurt him, but, when it comes to surgical operations, this old bromide has turned out to be no more than half a truth. 1994The first of these two opinions, Ruth v. Dight, 75 Wn.2d 660 , 453 P.2d 631 (1969), begins with a timeless description of the tension between the peculiar circumstances of medical malpractice and the rigid application of legal rules: There is a saying that what one does not know does not hurt him, but, when it comes to surgical operations, this old bromide has turned out to be no more than half a truth.	1	1994–1994

Statutes the citing opinions construe

WA § Wash. Rev. Code § 4.16.350 (7) WA § Wash. Rev. Code § 7.70.040 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NC 19 (1990–2022) WA 7 (1980–2024) CT 6 (1994–2019) IL 3 (1991–1993) MN 2 (1993–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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