Revised Code of Washington

Wash. Rev. Code § 11.106.070 (2026)

✓ current as of May 2026
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Upon the return date or at some later date fixed by the court if so requested by one or more of the parties, the court without the intervention of a jury and after hearing all the evidence submitted shall determine the correctness of the account and the validity and propriety of all actions of the trustee or trustees set forth in the account including the purchase, retention, and disposition of any of the property and funds of the trust, and shall render its decree either approving or disapproving the account or any part of it, and surcharging the trustee or trustees for all losses, if any, caused by negligent or wilful breaches of trust.
[ 1985 c 30 s 101. Prior: 1984 c 149 s 134; 1955 c 33 s 30.30.070; prior: 1951 c 226 s 7. Formerly RCW 30.30.070.]

Notes:

Short titleApplicationPurposeSeverability1985 c 30: See RCW 11.02.900 through 11.02.903.
SeverabilityEffective dates1984 c 149: See notes following RCW 11.02.005.
Notes of Decisions
Cited in 10 cases, 1996–2020 · leading case: Barovic v. Pemberton, 128 Wash. App. 196 (Wash. Ct. App. 2005).
Barovic v. Pemberton, 128 Wash. App. 196 (Wash. Ct. App. 2005). · cites it 8× “f 10 RCW 11.106.070 provides, in relevant part: [T]he court without the intervention of a jury and after hearing all the evidence submitted shall determine the correctness of the account and the validity and propriety of all actions of the trustee or trustees set forth in the…”
Barovic v. Pemberton, 114 P.3d 1230 (Wash. Ct. App. 2005). · cites it 8× “¶ 10 RCW 11.106.070 provides, in relevant part: [T]he court without the intervention of a jury and after hearing all the evidence submitted shall determine the correctness of the account and the validity and propriety of all actions of the trustee or trustees set forth in the…”
Sources for Sustainable Communities v. Bldg. Indus. Ass'n, 293 P.3d 1206 (Wash. Ct. App. 2013). “” RCW 11.106.070 (emphasis added); see also Restatement (Second) of Trusts § 205 (“If the trustee commits a breach of trust, he is chargeable with .”
In Re Est. of Ehlers, 911 P.2d 1017 (Wash. Ct. App. 1996). “” RCW 11.106.070. 4 Loraine cites RCW 11.106.”
Anderson v. Dussault, 333 P.3d 395 (Wash. 2014). “” RCW 11.106.070. The decree approving or rejecting the accounting, furthermore, “shall be deemed final, conclusive, and binding upon all the parties interested including all incompetent, unborn, and unascertained beneficiaries of the trust subject only to the right of appeal…”
Anderson v. Dussault, 310 P.3d 854 (Wash. Ct. App. 2013). · cites it 2× “RCW 11.106.070. ¶21 And if the superior court enters such a decree, it “shall be deemed final, conclusive, and binding upon all the *91 parties interested including all incompetent, unborn, and unascertained beneficiaries of the trust.”
In Re: Gust Rakus Credit Trust (Wash. Ct. App. 2020). · cites it 4× “” But, while Dianna’s objection to the Trustee’s accounting clearly turns on her interpretation of the 2005 deed, this argument does not transform her objection into an action to recover or possess real property.”
In Re The Guardianship Of Christopher Junk (Wash. Ct. App. 2016). · cites it 2× “” RCW 11.106.070. 2 No. 47283-0-II From October 2009 until January 2013, the superior court approved the trustee’s annual reports, which reflected the trust balances, the trustee’s fees, and the investment management fees.”
Donald Hoth v. Edward Hoth (Wash. Ct. App. 2020). “” RCW 11.106.070. This indicates that the decision to approve an accounting is a discretionary one and must be reviewed as such.”
Anderson v. Dussault (Wash. 2014). “" RCW 11.106.070. The decree approving or rejecting the accounting, furthermore, "shall be deemed final, conclusive, and binding upon all the parties interested including all incompetent, unborn, and unascertained beneficiaries of the trust subject only to the right of appeal…”
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