Revised Code of Washington
Wash. Rev. Code § 11.04.085 (2026)
Inheritance by adopted child
✓ current as of May 2026
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Notes of Decisions
Cited in 11
cases, 1970–2017 · leading case: In Re Estates of Donnelly, 502 P.2d 1163 (Wash. 1972).
In Re Estates of Donnelly, 502 P.2d 1163 (Wash. 1972). “As the trial court in its memorandum opinion and the Court of Appeals noted, the issue is whether RCW 11.04.085, which says that an adopted child shall not be deemed an heir of his natural parents, cuts off the inheritance from the natural grandparents as well.”
In Re Est. of Wiltermood, 472 P.2d 536 (Wash. 1970). “The statute, which is now codified as RCW 11.04.085, declares: A lawfully adopted child shall not be considered an “heir” of his natural parents for purposes of this title.”
In Re the Est. of Wagner, 748 P.2d 639 (Wash. Ct. App. 1987). “However, since pursuant to a 1939 Oregon decree Gutierrez was adopted by her natural maternal grandfather and his wife, Arthur and Helen Moulton, Gutierrez's adoption was raised as an affirmative defense under RCW 11.04.085 by the personal representative of Wagner's estate.”
Mitchell v. John Doe, 706 P.2d 1100 (Wash. Ct. App. 1985). “140. The confidentiality of the new, as well as the defunct, relationship *850 becomes virtually inviolate.”
In Re Est. of Fleming, 21 P.3d 281 (Wash. 2001). “For instance, RCW 11.04.085 provides that an adopted child is not an heir of his or her biological parents.”
Belancsik v. Overlake Mem'l Hosp., 492 P.2d 219 (Wash. 1971). “In sustaining the sufficiency of that title, we said, at page 242: The title of the probate code, of which RCW 11.04.085 was a part, needed only to give reasonable notice that the contents might affect the rights of inheritance.”
Kelly v. Iverson, 486 P.2d 1158 (Wash. Ct. App. 1971). “Prior to the enactment of RCW 11.04.085 in 1965, our Supreme Court held that a natural child could inherit from its natural parent notwithstanding its adoption by another.”
Marzan v. Kovacs, 143 Wash. 2d 412 (Wash. 2001). “For instance, RCW 11.04.085 provides that an adopted child is not an heir of his or her biological parents.”
In Re the Welfare of Sego, 499 P.2d 881 (Wash. Ct. App. 1972). “The blood of the attainted person was deemed to be corrupted, so that neither could he transmit his estate to his heirs, nor could they take by descent from the ancestor. In the instant case, Sego’s convictions do not prevent him from willing his property to his children, nor…”
In Re The Est. Of Deborah E. Reid (Wash. Ct. App. 2017). “260, we hold that as a result of his adoption, Saludares became the “child, legal heir, and lawful issue” of his adoptive parents and not of his biological mother “for all legal incidents,” including wrongful death actions.”
In Re the Est. of Couch, 726 P.2d 1007 (Wash. Ct. App. 1986). “RCW 11.04.085 provides: "A lawfully adopted child shall not be considered an 'heir' of his natural parents .”
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