Revised Code of Washington
Wash. Rev. Code § 11.12.230 (2026)
Intent of testator controlling
✓ current as of May 2026
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All courts and others concerned in the execution of last wills shall have due regard to the direction of the will, and the true intent and meaning of the testator, in all matters brought before them.
[ 1965 c 145 s 11.12.230. Prior: 1917 c 156 s 45; RRS s 1415; prior: Code 1881 s 1338; 1863 p 210 s 75; 1860 p 172 s 42.]
Notes of Decisions
Cited in 43
cases, 1954–2019 · leading case: Rathbone v. Est. of Rathbone (In Re Est. of Rathbone), 412 P.3d 1283 (Wash. 2018).
Rathbone v. Est. of Rathbone (In Re Est. of Rathbone), 412 P.3d 1283 (Wash. 2018). “Two days later, Glen filed a petition for order construing will under TEDRA and RCW 11.12.230, alleging Todd's distribution of the estate contradicted Ms.”
In Re The Matter Of The Est. Of: Bert W. Hook, 374 P.3d 215 (Wash. Ct. App. 2016). “Read in full, Estate of Elliott shows that a court will not concern itself with carrying out a testator’s wishes expressed in a will unless it is first established that the will is properly executed and admissible in probate.”
In Re Est. of Wright, 196 P.3d 1075 (Wash. Ct. App. 2008). “¶ 16 "[T]he paramount duty of a court in construing and interpreting the language of a will is to determine and implement the intent of the testator or testatrix.”
In Re Est. of Burks, 100 P.3d 328 (Wash. Ct. App. 2004). “We review a trial court's interpretation of a will de novo.”
In re the Est. of Burks, 124 Wash. App. 327 (Wash. Ct. App. 2004). “*331 ¶12 We review a trial court’s interpretation of a will de novo.”
Patterson v. Rosa, 147 Wash. App. 674 (Wash. Ct. App. 2008). “¶16 “[T]he paramount duty of a court in construing and interpreting the language of a will is to determine and implement the intent of the testator or testatrix.”
In Re Est. of Curry, 988 P.2d 505 (Wash. Ct. App. 1999). “2d 1324 (1991); see also RCW 11.12.230. “ ‘This intent should, if possible, be garnered from the language of the will itself.”
In Re the Est. of Tolson, 947 P.2d 1242 (Wash. Ct. App. 1997). “However, it was admitted as a valid foreign will in Washington. Applying collateral estoppel to the determination of domicile carries out the Decedent’s intent in this particular case.”
Sunderland v. Whitcomb, 55 P.3d 664 (Wash. Ct. App. 2002). “RCW 11.12.230; In re Estate of Bergau, 103 Wn.”
Woodard v. Gramlow, 95 P.3d 1244 (Wash. Ct. App. 2004). “CP at 39; see also RCW 11.12.230. Ms. Young apparently created the Young Family Living Trust at about the same time as she executed her will.”
In Re Est. of Campbell, 942 P.2d 1008 (Wash. Ct. App. 1997). “They contend that the will provides that Wilma’s life estate terminates if she should move from the family home and that the payout option must be exercised within a reasonable time following the move, or be forever lost.”
Griffith v. Sherry, 158 Wash. App. 69 (Wash. Ct. App. 2010). “It is on this issue of interpretation that we part ways with the trial court.”
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