liquidated claim (Washington) · Go Syfert
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liquidated claim in Washington

46 Washington opinions name it 2 courts 1928–2025 3 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 (9)

CaseFollowedCited
Weyerhaeuser Co. v. Commercial Union Insurancegreen
wash · 2000 · cited in 6 Washington opinions naming this issue, 2004–2013
2 sentences

2011A liquidated claim is one where the evidence furnishes data “which, if believed, make it possible to compute the amount due with exactness, without reliance on opinion or discretion.” Weyerhaeuser, 142 Wn.2d at 685 .

2011A liquidated claim is one where the evidence furnishes data "which, if believed, make it possible to compute the amount due with exactness, without reliance on opinion or discretion." Weyerhaeuser, 142 Wash.2d at 685 , 15 P.3d 115 .

26
McConnell v. Mothers Work, Inc.green
washctapp · 2006 · cited in 2 Washington opinions naming this issue, 2007–2007
2 sentences

2007McConnell v. Mothers Work, Inc., 131 Wash.App. 525, 536 , 128 P.3d 128 (2006) ("Damages are liquidated if the evidence furnishes data that, if believed, made it possible to compute the amount owed with exactness.").

2007McConnell v. Mothers Work, Inc., 131 Wn.

22
Prier v. Refrigeration Engineering Co.green
wash · 1968 · cited in 19 Washington opinions naming this issue, 1991–2025
2 sentences

2025A liquidated claim is one where “‘where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion.’” Hansen, 107 Wn.2d at 472 (quoting Prier v. Refrigeration Eng’g Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968)).

2025A liquidated claim is one where “‘where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion.’” Hansen, 107 Wn.2d at 472 (quoting Prier v. Refrigeration Eng’g Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968)).

119
Hansen v. Rothausgreen
wash · 1986 · cited in 8 Washington opinions naming this issue, 1996–2025
2 sentences

2025A liquidated claim is one where “‘where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion.’” Hansen, 107 Wn.2d at 472 (quoting Prier v. Refrigeration Eng’g Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968)).

2007A liquidated claim exists when “the amount of prejudgment interest can be determined from the evidence with exactness and without reliance on opinion or discretion.” Bostain, 159 Wn.2d at 723 (citing Hansen, 107 Wn.2d at 472 ). “ ‘A dispute over the claim, in whole or in part, does not change the character of a liquidated claim to unliquidated.’ ” Id. (quoting Hansen, 107 Wn.2d at 472 ).

18
Weyerhaeuser Co. v. Commercial Union Ins.green
wash · 2001 · cited in 4 Washington opinions naming this issue, 2004–2013
2 sentences

2011A liquidated claim is one where the evidence furnishes data "which, if believed, make it possible to compute the amount due with exactness, without reliance on opinion or discretion." Weyerhaeuser, 142 Wash.2d at 685 , 15 P.3d 115 .

2004Weyerhaeuser, 142 Wash.2d at 685 , 15 P.3d 115 ; Prier, 74 Wash.2d at 33 , 442 P.2d 621 . "[T]he defendant's belief that he or she never owed the money in the first place has never been an excuse for avoiding interest on a liquidated claim." Colonial Imports v. Carlton N.W., Inc., 83 Wash.App. 229, 247 , 921 P.2d 575 (1996) (citing Prier, 74 Wash.2d at 34 , 442 P.2d 621 ).

14
Mall Tool Co. v. Far West Equipment Co.green
wash · 1954 · cited in 3 Washington opinions naming this issue, 1967–2025
2 sentences

2001Mall Tool, 45 Wn.2d at 178-79 . the court stated, however, that if the counterclaim had been for defective workmanship in the goods giving rise to the liquidated claim, the offset exception would apply.

1967Co., 45 Wn.2d 158, 176 , 273 P.2d 652 (1954), on which plaintiff relies in support of the trial court’s allowance of interest, that interest from the date performance was due is allowable (1) when an amount claimed is “liquidated” or (2) when the amount of an “unliquidated” claim is for “[A]n amount due upon a specific contract for the payment of money and the amount due is determinable by computation with reference to a fixed standard contained in the contract, without reliance upon opinion or discretion ” We also cited with approval McCormick on Damages § 54, which defines a liquidated claim

13
McConnell v. Mothers Work, Inc.green
washctapp · 2006 · cited in 1 Washington opinions naming this issue, 2007–2007
1 sentence

2007McConnell v. Mothers Work, Inc., 131 Wash.App. 525, 536 , 128 P.3d 128 (2006) ("Damages are liquidated if the evidence furnishes data that, if believed, made it possible to compute the amount owed with exactness.").

11
Auther Jones v. Spentonbush-Red Star Companygreen
ca2 · 1998 · cited in 1 Washington opinions naming this issue, 2001–2001
1 sentence

2001Schoenbaum, Admiralty & Maritime Law § 5-21, at 246 (3d ed. 2000) ("The Supreme Court has decided that awarding prejudgment interest is a basic principle of admiralty law and is not a penalty."). [89] Cement Div., 515 U.S. at 195-96 , 115 S.Ct. 2091 . [90] Cement Div., 515 U.S. at 195 , 115 S.Ct. 2091 ; Jones v. Spentonbush-Red Star Co., 155 F.3d 587, 593 (2d Cir.1998). [91] 358 U.S. 588 , 79 S.Ct. 503 , 3 L.Ed.2d 524 (1959). [92] Tungus, 358 U.S. at 592 , 79 S.Ct. 503 . [93] Tungus, 358 U.S. at 593 , 79 S.Ct. 503 . [94] 138 Wash. 390 , 244 P. 723 (1926). [95] Roswall, 138 Wash. at 397 , 244 P

11
McGovern v. Martzgreen
dcd · 1960 · cited in 1 Washington opinions naming this issue, 1989–1989
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (32)

CaseCitedYears
Colonial Imports v. Carlton Northwest, Inc. green
washctapp · 1996
2 sentences

2004Weyerhaeuser, 142 Wash.2d at 685 , 15 P.3d 115 ; Prier, 74 Wash.2d at 33 , 442 P.2d 621 . "[T]he defendant's belief that he or she never owed the money in the first place has never been an excuse for avoiding interest on a liquidated claim." Colonial Imports v. Carlton N.W., Inc., 83 Wash.App. 229, 247 , 921 P.2d 575 (1996) (citing Prier, 74 Wash.2d at 34 , 442 P.2d 621 ).

2004Weyerhaeuser, 142 Wn.2d at 685 ; Prier, 74 Wn.2d at 33 . “[T]he defendant’s belief that he or she never owed the money in the first place has never been an excuse for avoiding interest on a liquidated claim.” Colonial Imports v. Carlton N.W., Inc., 83 Wn.

42004–2009
Hadley v. Maxwell green
washctapp · 2004
2 sentences

2009And "a liquidated claim remains so even if the defendant is partially successful in reducing his or her share of liability." Id. at 144, 84 P.3d 286 . ¶ 58 The claim here was for attorney fees under an attorney fee agreement.

2008Indeed, "a liquidated claim remains so even if the defendant is partially successful in reducing his or her share of liability." Hadley v. Maxwell, 120 Wash.App. 137, 144 , 84 P.3d 286 (2004).

42007–2009
Hadley v. Maxwell green
washctapp · 2004
2 sentences

2008Indeed, “a liquidated claim remains so even if the defendant is partially successful in reducing his or her share of liability.” Hadley v. Maxwell, 120 Wn.

2008Indeed, "a liquidated claim remains so even if the defendant is partially successful in reducing his or her share of liability." Hadley v. Maxwell, 120 Wash.App. 137, 144 , 84 P.3d 286 (2004).

42007–2008
Gemini Farms L.L.C. v. Smith-Kem Ellensburg, Inc. green
washctapp · 2001
2 sentences

2025Under those circumstances, the amount of a liquidated claim may be reduced by the amount of an unliquidated counterclaim, and interest is “payable on only the amount remaining after setoff.” Gemini Farms LLC v. Smith-Kem Ellensburg, Inc., 104 Wn.

2025App. 267, 269 , 16 P.3d 82 (2001); see also Mall Tool, 45 Wn.2d at 177 .

22024–2025
King County v. Puget Sound Power & Light Co. green
washctapp · 1993
2 sentences

2007A liquidated claim is one "where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion." Car Wash Enter., *50 Inc. v. Kampanos, 74 Wash.App. 537, 548-49 , 874 P.2d 868 (1994), quoting King County v. Puget Sound Power & Light Co., 70 Wash. App. 58, 61 , 852 P.2d 313 , review denied, 122 Wash.2d 1017 , 863 P.2d 1352 (1993).

2007A liquidated claim is one "where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion." Car Wash Enter., *50 Inc. v. Kampanos, 74 Wash.App. 537, 548-49 , 874 P.2d 868 (1994), quoting King County v. Puget Sound Power & Light Co., 70 Wash. App. 58, 61 , 852 P.2d 313 , review denied, 122 Wash.2d 1017 , 863 P.2d 1352 (1993).

22007–2007
Bostain v. Food Express, Inc. green
wash · 2007
2 sentences

2007A liquidated claim exists when "the amount of prejudgment interest can be determined from the evidence with exactness and without reliance on opinion or discretion." Bostain, 159 Wash.2d at 723 , 153 P.3d 846 (citing Hansen, 107 Wash.2d at 472 , 730 P.2d 662 ). "`A dispute over the claim, in whole or in part, does not change the character of a liquidated claim to unliquidated.'" Id. (quoting Hansen, 107 Wash.2d at 472 , 730 P.2d 662 ).

2007A liquidated claim exists when “the amount of prejudgment interest can be determined from the evidence with exactness and without reliance on opinion or discretion.” Bostain, 159 Wn.2d at 723 (citing Hansen, 107 Wn.2d at 472 ). “ ‘A dispute over the claim, in whole or in part, does not change the character of a liquidated claim to unliquidated.’ ” Id. (quoting Hansen, 107 Wn.2d at 472 ).

22007–2007
Car Wash Enterprises, Inc. v. Kampanos green
washctapp · 1994
2 sentences

2007A liquidated claim is one "where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion." Car Wash Enter., *50 Inc. v. Kampanos, 74 Wash.App. 537, 548-49 , 874 P.2d 868 (1994), quoting King County v. Puget Sound Power & Light Co., 70 Wash. App. 58, 61 , 852 P.2d 313 , review denied, 122 Wash.2d 1017 , 863 P.2d 1352 (1993).

2007A liquidated claim is one "" "where the evidence furnishes data which, if believed, makes it possible to compute the amount with exactness, without reliance on opinion or discretion.’ ” Car Wash Enters., Inc. v. Kampanos, 74 Wn.

22007–2007
City of Milwaukee v. Cement Division, National Gypsum Co. green
scotus · 1995
2 sentences

2001A liquidated claim is one whose "exact amount is fixed and known." Prier, 74 Wash.2d at 32 , 442 P.2d 621 . [87] Cement Div., 515 U.S. at 197 , 115 S.Ct. 2091 . [88] City of Milwaukee v. Cement Div., Nat'l Gypsum Co., 515 U.S. 189, 196 , 115 S.Ct. 2091 , 132 L.Ed.2d 148 (1995) (holding neither a good faith dispute over liability nor the existence of mutual fault justifies denying prejudgment interest in an admiralty collision case); see also Thomas J.

2001A liquidated claim is one whose "exact amount is fixed and known." Prier, 74 Wash.2d at 32 , 442 P.2d 621 . [87] Cement Div., 515 U.S. at 197 , 115 S.Ct. 2091 . [88] City of Milwaukee v. Cement Div., Nat'l Gypsum Co., 515 U.S. 189, 196 , 115 S.Ct. 2091 , 132 L.Ed.2d 148 (1995) (holding neither a good faith dispute over liability nor the existence of mutual fault justifies denying prejudgment interest in an admiralty collision case); see also Thomas J.

22001–2001
City of Seattle v. Dyad Construction, Inc. green
washctapp · 1977
2 sentences

1981Seattle v. Dyad Constr., Inc., 17 Wn.

1979Seattle v. Dyad Constr., Inc., 17 Wn.

21979–1981
Buckner, Inc. v. Berkey Irrigation Supply green
washctapp · 1998
1 sentence

2025Supply, 89 Wn.

12025–2025
Dautel v. Heritage Home Center, Inc. green
washctapp · 1997
1 sentence

2018Dautel, 89 Wn.

12018–2018
Coast Trading Co. v. Parmac, Inc. green
washctapp · 1978
1 sentence

2015Inc.. 21 Wn.

12015–2015
Unigard Ins. Co. v. MUTUAL OF ENUMCLAW INS. green
washctapp · 2011
1 sentence

2013“A liquidated claim is one where the evidence furnishes data ‘which, if believed, make it possible to compute the amount due with exactness, without reliance on opinion or discretion.’ ” Id. (quoting Weyerhaeuser Co. v. Commercial Union Ins.

12013–2013
Unigard Insurance v. Mutual of Enumclaw Insurance green
washctapp · 2011
1 sentence

2013"A liquidated claim is one where the evidence furnishes data 'which, if believed, make it possible to compute the amount due with 28 No. 30544-9-111 Hidalgo v. Barker exactness, without reliance on opinion or discretion.'" Id. (quoting Weyerhaeuser Co. v. Commercial Union Ins.

12013–2013
Magana v. Hyundai Motor America green
washctapp · 2004
1 sentence

2007Magana, 123 Wash.App. at 313 , 94 P.3d 987 .

12007–2007
Bostain v. Food Exp., Inc. green
wash · 2007
1 sentence

2007A liquidated claim exists when "the amount of prejudgment interest can be determined from the evidence with exactness and without reliance on opinion or discretion." Bostain, 159 Wash.2d at 723 , 153 P.3d 846 (citing Hansen, 107 Wash.2d at 472 , 730 P.2d 662 ). "`A dispute over the claim, in whole or in part, does not change the character of a liquidated claim to unliquidated.'" Id. (quoting Hansen, 107 Wash.2d at 472 , 730 P.2d 662 ).

12007–2007
Magana v. Hyundai Motor America green
washctapp · 2004
1 sentence

2007Magana, 123 Wash.App. at 313 , 94 P.3d 987 .

12007–2007
The Tungus v. Skovgaard red
scotus · 1959
2 sentences

2001Schoenbaum, Admiralty & Maritime Law § 5-21, at 246 (3d ed. 2000) ("The Supreme Court has decided that awarding prejudgment interest is a basic principle of admiralty law and is not a penalty."). [89] Cement Div., 515 U.S. at 195-96 , 115 S.Ct. 2091 . [90] Cement Div., 515 U.S. at 195 , 115 S.Ct. 2091 ; Jones v. Spentonbush-Red Star Co., 155 F.3d 587, 593 (2d Cir.1998). [91] 358 U.S. 588 , 79 S.Ct. 503 , 3 L.Ed.2d 524 (1959). [92] Tungus, 358 U.S. at 592 , 79 S.Ct. 503 . [93] Tungus, 358 U.S. at 593 , 79 S.Ct. 503 . [94] 138 Wash. 390 , 244 P. 723 (1926). [95] Roswall, 138 Wash. at 397 , 244 P

2001Schoenbaum, Admiralty & Maritime Law § 5-21, at 246 (3d ed. 2000) ("The Supreme Court has decided that awarding prejudgment interest is a basic principle of admiralty law and is not a penalty."). [89] Cement Div., 515 U.S. at 195-96 , 115 S.Ct. 2091 . [90] Cement Div., 515 U.S. at 195 , 115 S.Ct. 2091 ; Jones v. Spentonbush-Red Star Co., 155 F.3d 587, 593 (2d Cir.1998). [91] 358 U.S. 588 , 79 S.Ct. 503 , 3 L.Ed.2d 524 (1959). [92] Tungus, 358 U.S. at 592 , 79 S.Ct. 503 . [93] Tungus, 358 U.S. at 593 , 79 S.Ct. 503 . [94] 138 Wash. 390 , 244 P. 723 (1926). [95] Roswall, 138 Wash. at 397 , 244 P

12001–2001
Roswall v. Grays Harbor Stevedore Co. green
wash · 1926
2 sentences

2001Schoenbaum, Admiralty & Maritime Law § 5-21, at 246 (3d ed. 2000) ("The Supreme Court has decided that awarding prejudgment interest is a basic principle of admiralty law and is not a penalty."). [89] Cement Div., 515 U.S. at 195-96 , 115 S.Ct. 2091 . [90] Cement Div., 515 U.S. at 195 , 115 S.Ct. 2091 ; Jones v. Spentonbush-Red Star Co., 155 F.3d 587, 593 (2d Cir.1998). [91] 358 U.S. 588 , 79 S.Ct. 503 , 3 L.Ed.2d 524 (1959). [92] Tungus, 358 U.S. at 592 , 79 S.Ct. 503 . [93] Tungus, 358 U.S. at 593 , 79 S.Ct. 503 . [94] 138 Wash. 390 , 244 P. 723 (1926). [95] Roswall, 138 Wash. at 397 , 244 P

2001Schoenbaum, Admiralty & Maritime Law § 5-21, at 246 (3d ed. 2000) ("The Supreme Court has decided that awarding prejudgment interest is a basic principle of admiralty law and is not a penalty."). [89] Cement Div., 515 U.S. at 195-96 , 115 S.Ct. 2091 . [90] Cement Div., 515 U.S. at 195 , 115 S.Ct. 2091 ; Jones v. Spentonbush-Red Star Co., 155 F.3d 587, 593 (2d Cir.1998). [91] 358 U.S. 588 , 79 S.Ct. 503 , 3 L.Ed.2d 524 (1959). [92] Tungus, 358 U.S. at 592 , 79 S.Ct. 503 . [93] Tungus, 358 U.S. at 593 , 79 S.Ct. 503 . [94] 138 Wash. 390 , 244 P. 723 (1926). [95] Roswall, 138 Wash. at 397 , 244 P

12001–2001
Redfield v. Ystalyfera Iron Co. green
scotus · 1884
2 sentences

1996In Redfield v. Ystalyfera Iron Co. 110 U.S. 174, 176 , 3 S.Ct. 570, 571-72 , 28 L.Ed. 109 (1884) the United States Supreme Court disallowed prejudgment interest on a liquidated claim where the claimant had unreasonably delayed prosecution of his claim.

1996In Redfield v. Ystalyfera Iron Co. 110 U.S. 174, 176 , 3 S.Ct. 570, 571-72 , 28 L.Ed. 109 (1884) the United States Supreme Court disallowed prejudgment interest on a liquidated claim where the claimant had unreasonably delayed prosecution of his claim.

11996–1996
Board of Comm'rs of Jackson Cty. v. United States green
scotus · 1939
11996–1996
Getty Oil Co. v. Catalytic, Inc. green
delsuperct · 1986
11996–1996
Blau v. Lehman green
scotus · 1962
11996–1996
Kiewit-Grice v. State green
washctapp · 1995
2 sentences

1996A liquidated claim occurs when the "evidence furnishes data which, if believed, makes it possible to compute the amount [owed] with exactness, without reliance on opinion or discretion.’ ” Kiewit-Grice v. State, 77 Wn.

1996App. 867, 872 , 895 P.2d 6 (quoting Prier v. Refrigeration Eng’g Co., 74 Wn.2d 25, 32 , 442 P.2d 621 (1968)), review denied, 127 Wn.2d 1018 (1995).

11996–1996
Curtis v. Security Bank green
washctapp · 1993
2 sentences

1996We reject this contention for two reasons: first, the lease does not require Ernst to provide any particular type of information; second, the landlord testified at trial that none of the information presented at trial would have changed the decision not to consent, even if the information had been presented at some earlier time. [12] In his concurring opinion, infra, Judge Forrest challenges abuse of discretion as the standard of review of a trial court's decision to grant or deny prejudgment interest, pointing out that Curtis, 69 Wash.App. at 20 , 847 P.2d 507 , which we cite for that proposi

1996We reject this contention for two reasons: first, the lease does not require Ernst to provide any particular type of information; second, the landlord testified at trial that none of the information presented at trial would have changed the decision not to consent, even if the information had been presented at some earlier time. [12] In his concurring opinion, infra, Judge Forrest challenges abuse of discretion as the standard of review of a trial court's decision to grant or deny prejudgment interest, pointing out that Curtis, 69 Wash.App. at 20 , 847 P.2d 507 , which we cite for that proposi

11996–1996
American Air Filter Co. v. Washington Public Power Supply System neutral
washctapp · 1990
11993–1993
Jones v. Sonny Gerber Auto Sales, Inc. green
ned · 1976
11989–1989
Wright v. City of Tacoma green
wash · 1915
11954–1954
Judd v. Dike neutral
minn · 1883
11928–1928
Miller v. Washington County green
tenn · 1920
11928–1928
Shelton v. Harrison green
· 1914
11928–1928
Briggs v. Childs neutral
me · 1923
11928–1928

Statutes the citing opinions construe

WA § Wash. Rev. Code § 4.56.110 (10) WA § Wash. Rev. Code § 49.48.030 (7) WA § Wash. Rev. Code § 2.06.040 (5) WA § Wash. Rev. Code § 4.84.330 (5) USC § 29u.s.c.213 (4) WA § Wash. Rev. Code § 19.52.010 (4) WA § Wash. Rev. Code § 19.52.020 (4) WA § Wash. Rev. Code § 4.22.040 (4) WA § Wash. Rev. Code § 49.46.090 (4) WA § Wash. Rev. Code § 49.52.070 (4) WA § Wash. Rev. Code § 4.84.010 (3)

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

AZ 50 (1972–2025) WA 46 (1928–2025) TX 44 (1912–2026) CA 21 (1933–2025) WY 21 (1976–2025) GA 20 (1960–2026) LA 19 (1933–2022) PA 14 (1924–2023) MO 13 (1949–2007) NJ 13 (1942–1993) OH 12 (1932–2016) NY 10 (1887–2022) KY 10 (1945–2024) MN 9 (1961–1996) MD 8 (1960–2007) WI 8 (1934–2019) CO 8 (1968–2021) IL 7 (1901–2017) KS 6 (1934–2025) FL 6 (1979–2001) DC 6 (1979–2013) MS 5 (1963–1998) IN 5 (1914–1974) MI 5 (1897–1939) ID 4 (1999–2021) OR 4 (1939–1987) IA 4 (1911–1947) NE 3 (1991–2019) DE 3 (1953–1969) SC 3 (1931–1942) OK 3 (1961–2000) VA 2 (1940–1960) WV 2 (1914–1985) SD 2 (1980–1986) NM 2 (1936–1975) TN 2 (2010–2015) MA 2 (1938–1939)

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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