Revised Code of Washington
Wash. Rev. Code § 11.28.237 (2026)
✓ current as of May 2026
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*** CHANGE IN 2026 *** (SEE 2445.SL) ***
(1) Within twenty days after appointment, the personal representative of the estate of a decedent shall cause written notice of his or her appointment and the pendency of said probate proceedings, to be served personally or by mail to each heir, legatee and devisee of the estate and each beneficiary or transferee of a nonprobate asset of the decedent whose names and addresses are known to him or her, and proof of such mailing or service shall be made by affidavit and filed in the cause. If a trust is a legatee or devisee of the estate or a beneficiary or transferee of a nonprobate asset of the decedent, then notice to the trustee is sufficient.
(2) If the personal representative does not otherwise give notice to creditors under chapter 11.40 RCW within thirty days after appointment, the personal representative shall cause written notice of his or her appointment and the pendency of the probate proceedings to be mailed to the state of Washington department of social and health services' office of financial recovery, and proof of the mailing shall be made by affidavit and filed in the cause.
[ 2011 c 327 s 2; 1997 c 252 s 85; 1994 c 221 s 24; 1977 ex.s. c 234 s 6; 1974 ex.s. c 117 s 30; 1969 c 70 s 2; 1965 c 145 s 11.28.237. Prior: 1955 c 205 s 13, part; RCW 11.76.040, part.]
Notes:
Application—Effective date—2011 c 327: See notes following RCW 11.103.020.
Effective dates—1994 c 221: See note following RCW 11.100.035.
Application, effective date—Severability—1977 ex.s. c 234: See notes following RCW 11.20.020.
Application, construction—Severability—Effective date—1974 ex.s. c 117: See RCW 11.02.080 and notes following.
Notes of Decisions
Cited in 14
cases (1 in the last 5 years), 1971–2025 · leading case: Hesthagen v. Harby, 481 P.2d 438 (Wash. 1971).
Hesthagen v. Harby, 481 P.2d 438 (Wash. 1971). “Blomberg was appointed administrator, notice of his appointment forwarded to Gunda and Harold in accordance with RCW 11.28.237 and 11.76.040, and a bond posted.”
In Re Est. of Little, 113 P.3d 505 (Wash. Ct. App. 2005). “RCW 11.28.237(1). [2] Although Little and his nieces *507 and nephews had been out of touch for a long time, the record reflects that Vannoy was aware of at least one of them, a nephew named Byron Winn who lived in Seattle.”
In re the Est. of Little, 127 Wash. App. 915 (Wash. Ct. App. 2005). “” RCW 11.28.237(1). 2 Although Little and his nieces and *918 nephews had been out of touch for a long time, the record reflects that Vannoy was aware of at least one of them, a nephew named Byron Winn who lived in Seattle.”
Est. of Toth v. Cooke, 955 P.2d 856 (Wash. Ct. App. 1998). “The petition was dismissed as time-barred and the petitioners appeal, contending (1) CR 6(e) applies to extend the limitation period by three days, (2) common law allowing for a reasonable time to receive notice by mail applies to probate proceedings, and (3) notice pursuant to…”
In re the Est. of Toth, 138 Wash. 2d 650 (Wash. 1999). “In accordance with RCW 11.28.237, Cooke mailed notice of his appointment as personal representative of the estate to Toth’s relatives, Juba Webb, Bobbi Szabo, and Ilona Webb (the Webbs).”
In Re Est. of Toth, 981 P.2d 439 (Wash. 1999). “In accordance with RCW 11.28.237, Cooke mailed notice of his appointment as personal representative of the estate to Toth's relatives, Julia Webb, Bobbi Szabo, and Ilona Webb (the Webbs).”
In Re the Est. of Walker, 521 P.2d 43 (Wash. Ct. App. 1974). “In connection with this omission, the executor had also failed to mail to these same legatees notice of its appointment as executor and notice of the pendency of the probate as it was required to do by RCW 11.28.237. This omission was brought to the trial court’s attention by…”
In Re the Est. of Young, 598 P.2d 7 (Wash. Ct. App. 1979). “Young The notice is in conformity with RCW 11.28.237: Within twenty days after appointment, the personal representative of the estate of a decedent shall cause written notice of his appointment and the pendency of said probate proceedings, to be served personally or by mail to…”
Pitzer v. Union Bank of California, 969 P.2d 113 (Wash. Ct. App. 1998). “2d 856 (1998) (failure of personal representative to timely notify interested parties in conformity with RCW 11.28.237 denies them due process and renders the decree of distribution void) (citation omitted).”
In Re The Matter Of The Est. Of Edward William Coaker (Wash. Ct. App. 2016). “Bill makes numerous arguments why the statute of limitations should be tolled, making his will contest timely.”
Est. of Mary Teresa Maiuri (Wash. Ct. App. 2018). “34749-4-III In re Estate of Maiuri The trial court did not abuse its discretion when it reappointed Michael Maiuri as personal representative RCW 11.28.237 requires the personal representative of an estate to cause written notice of the appointment and the pendency of the…”
Est. Of Sassan Sanai Md - Astrid Sanai Pr v. Cyrus Sanai (Wash. Ct. App. 2019). “The statute requires the personal representative to file the document appointing an agent.22 Astrid filed the document appointing McCarthy, and the document included McCarthy's business address to facilitate service.”
— Wash. Rev. Code § 11.28.237(1) — 3 cases
In Re Est. of Little, 113 P.3d 505 (Wash. Ct. App. 2005). “RCW 11.28.237(1). [2] Although Little and his nieces *507 and nephews had been out of touch for a long time, the record reflects that Vannoy was aware of at least one of them, a nephew named Byron Winn who lived in Seattle.”
In re the Est. of Little, 127 Wash. App. 915 (Wash. Ct. App. 2005). “” RCW 11.28.237(1). 2 Although Little and his nieces and *918 nephews had been out of touch for a long time, the record reflects that Vannoy was aware of at least one of them, a nephew named Byron Winn who lived in Seattle.”
Est. Of Sassan Sanai Md - Astrid Sanai Pr v. Cyrus Sanai (Wash. Ct. App. 2019). “The statute requires the personal representative to file the document appointing an agent.22 Astrid filed the document appointing McCarthy, and the document included McCarthy's business address to facilitate service.”
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