Wash. Rev. Code » Title 11 · Chapter 11.12
Revised Code of Washington

Wash. Rev. Code § 11.12.255 (2026)

Incorporation by reference

✓ current as of May 2026
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A will may incorporate by reference any writing in existence when the will is executed if the will itself manifests the testator's intent to incorporate the writing and describes the writing sufficiently to permit its identification. In the case of any inconsistency between the writing and the will, the will controls.
[ 1985 c 23 s 3. Prior: 1984 c 149 s 6.]

Notes:

Short title—Application—1985 c 30: See RCW 11.02.900 through 11.02.903.
Purpose—Application—Severability—1985 c 23: See notes following RCW 11.12.250.
Severability—Effective dates—1984 c 149: See notes following RCW 11.02.005.
Notes of Decisions
Cited in 4 cases, 2004–2019 · leading case: In Re The Est. Of Constance E. Little Roxanne Trees, Res. v. Renae Roberson, App., 444 P.3d 23 (Wash. Ct. App. 2019).
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In Re The Est. Of Constance E. Little Roxanne Trees, Res. v. Renae Roberson, App., 444 P.3d 23 (Wash. Ct. App. 2019). · cites it 6× “The July 20, 2011 separate writing was executed contemporaneously with the Will dated July 20, 2011 and is incorporated by reference in the Will per RCW 11.12.255. However, it is premature to order any reductions to the distributive share of Renae Roberson because the issue of…”
Woodard v. Gramlow, 95 P.3d 1244 (Wash. Ct. App. 2004). “Young clearly intended for Attachment 1 to be part of her Last Will and Testament as evidenced by her handwritten notation on page 2 (the witness signature page), which states: “4 pages including Attachment.”
Woodard v. Gramlow, 95 P.3d 1244 (Wash. Ct. App. 2004). “Young clearly intended for Attachment 1 *1247 to be part of her Last Will and Testament as evidenced by her handwritten notation on page 2 (the witness signature page), which states: "4 pages including Attachment.”
In Re The Est. Of: Michael James Scott, Jr. & Nadine Irene Scott (Wash. Ct. App. 2019). · cites it 2× “They dispute whether or not the 2015 Codicils incorporate the July 10, 2008 purported wills by reference.”
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