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.
| Case | Followed | Cited |
|---|---|---|
Weyerhaeuser Co. v. Commercial Union Insurancegreen2 sentences2011A 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 . | 2 | 6 |
McConnell v. Mothers Work, Inc.green2 sentences2007McConnell 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. | 2 | 2 |
Prier v. Refrigeration Engineering Co.green2 sentences2025A 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)). | 1 | 19 |
Hansen v. Rothausgreen2 sentences2025A 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 ). | 1 | 8 |
Weyerhaeuser Co. v. Commercial Union Ins.green2 sentences2011A 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 ). | 1 | 4 |
Mall Tool Co. v. Far West Equipment Co.green2 sentences2001Mall 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 | 1 | 3 |
McConnell v. Mothers Work, Inc.green1 sentence2007McConnell 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."). | 1 | 1 |
Auther Jones v. Spentonbush-Red Star Companygreen1 sentence2001Schoenbaum, 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 | 1 | 1 |
| McGovern v. Martzgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Colonial Imports v. Carlton Northwest, Inc.
green
2 sentences2004Weyerhaeuser, 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. | 4 | 2004–2009 |
Hadley v. Maxwell
green
2 sentences2009And "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). | 4 | 2007–2009 |
Hadley v. Maxwell
green
2 sentences2008Indeed, “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). | 4 | 2007–2008 |
Gemini Farms L.L.C. v. Smith-Kem Ellensburg, Inc.
green
2 sentences2025Under 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 . | 2 | 2024–2025 |
King County v. Puget Sound Power & Light Co.
green
2 sentences2007A 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). | 2 | 2007–2007 |
Bostain v. Food Express, Inc.
green
2 sentences2007A 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 ). | 2 | 2007–2007 |
Car Wash Enterprises, Inc. v. Kampanos
green
2 sentences2007A 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. | 2 | 2007–2007 |
City of Milwaukee v. Cement Division, National Gypsum Co.
green
2 sentences2001A 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. | 2 | 2001–2001 |
City of Seattle v. Dyad Construction, Inc.
green
2 sentences1981Seattle v. Dyad Constr., Inc., 17 Wn. 1979Seattle v. Dyad Constr., Inc., 17 Wn. | 2 | 1979–1981 |
Buckner, Inc. v. Berkey Irrigation Supply
green
1 sentence2025Supply, 89 Wn. | 1 | 2025–2025 |
Dautel v. Heritage Home Center, Inc.
green
1 sentence2018Dautel, 89 Wn. | 1 | 2018–2018 |
Coast Trading Co. v. Parmac, Inc.
green
1 sentence2015Inc.. 21 Wn. | 1 | 2015–2015 |
Unigard Ins. Co. v. MUTUAL OF ENUMCLAW INS.
green
1 sentence2013“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. | 1 | 2013–2013 |
Unigard Insurance v. Mutual of Enumclaw Insurance
green
1 sentence2013"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. | 1 | 2013–2013 |
Magana v. Hyundai Motor America
green
1 sentence2007Magana, 123 Wash.App. at 313 , 94 P.3d 987 . | 1 | 2007–2007 |
Bostain v. Food Exp., Inc.
green
1 sentence2007A 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 ). | 1 | 2007–2007 |
Magana v. Hyundai Motor America
green
1 sentence2007Magana, 123 Wash.App. at 313 , 94 P.3d 987 . | 1 | 2007–2007 |
The Tungus v. Skovgaard
red
2 sentences2001Schoenbaum, 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 | 1 | 2001–2001 |
Roswall v. Grays Harbor Stevedore Co.
green
2 sentences2001Schoenbaum, 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 | 1 | 2001–2001 |
Redfield v. Ystalyfera Iron Co.
green
2 sentences1996In 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. | 1 | 1996–1996 |
| Board of Comm'rs of Jackson Cty. v. United States green | 1 | 1996–1996 |
| Getty Oil Co. v. Catalytic, Inc. green | 1 | 1996–1996 |
| Blau v. Lehman green | 1 | 1996–1996 |
Kiewit-Grice v. State
green
2 sentences1996A 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). | 1 | 1996–1996 |
Curtis v. Security Bank
green
2 sentences1996We 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 | 1 | 1996–1996 |
| American Air Filter Co. v. Washington Public Power Supply System neutral | 1 | 1993–1993 |
| Jones v. Sonny Gerber Auto Sales, Inc. green | 1 | 1989–1989 |
| Wright v. City of Tacoma green | 1 | 1954–1954 |
| Judd v. Dike neutral | 1 | 1928–1928 |
| Miller v. Washington County green | 1 | 1928–1928 |
| Shelton v. Harrison green | 1 | 1928–1928 |
| Briggs v. Childs neutral | 1 | 1928–1928 |
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.
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.