Wash. Rev. Code » Title 11 · Chapter 11.48
Revised Code of Washington

Wash. Rev. Code § 11.48.090 (2026)

Actions for recovery of property and on contract

✓ current as of May 2026
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Actions for the recovery of any property or for the possession thereof, and all actions founded upon contracts, may be maintained by and against personal representatives in all cases in which the same might have been maintained by and against their respective testators or intestates.
[ 1965 c 145 s 11.48.090. Prior: 1917 c 156 s 148; RRS s 1518; prior: Code 1881 s 1529; 1860 p 206 s 222; 1854 p 291 s 142.]

Notes:

Performance of decedent's contracts: Chapter 11.60 RCW.
Survival of actions: Chapter 4.20 RCW.
Notes of Decisions
Cited in 5 cases (2 in the last 5 years), 1994–2023 · leading case: Est. of Coggins ex rel. Brooks v. Wapato Point Mgmt. Co. Health & Welfare Plan, 22 F. Supp. 3d 1152 (E.D. Wash. 2014).
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Est. of Coggins ex rel. Brooks v. Wapato Point Mgmt. Co. Health & Welfare Plan, 22 F. Supp. 3d 1152 (E.D. Wash. 2014). “” RCW 11.48.090 (emphasis added). See also 31 Am.”
Est. Of David Lynch, App V. Washington Healthcare Auth., Resp (Wash. Ct. App. 2023). · cites it 4× “200, in his or her hands as rapidly and as quickly as possible, without sacrifice to the probate or nonprobate estate.”
Gary Waddoups v. Nationwide Life Ins. Co. (Wash. Ct. App. 2016). · cites it 3× “RCW 11.48.090 repeats the dictates ofRCW 11.”
Est. of Phillips v. Nyhus, 874 P.2d 154 (Wash. 1994). “10 Pursuant to *83 RCW 11.48.090, as personal representative, Mr.”
Robert Hays, V. Hays Elliott Props., Llc (Wash. Ct. App. 2023). “actions [that] pertain to the management and settlement of the estate” and sue to recover debts or property); RCW 11.48.090 (“[A]ll actions founded upon contracts[] may be maintained by and against personal representatives in all cases in which the same might have been…”
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