Revised Code of Washington
Wash. Rev. Code § 11.84.020 (2026)
Slayer or abuser not to benefit from death
✓ current as of May 2026
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No slayer or abuser shall in any way acquire any property or receive any benefit as the result of the death of the decedent, but such property shall pass as provided in the sections following.
Notes of Decisions
Cited in 22
cases (2 in the last 5 years), 1978–2023 · leading case: Eaden v. Est. of Evans, 181 Wash. App. 436 (Wash. Ct. App. 2014).
Eaden v. Est. of Evans, 181 Wash. App. 436 (Wash. Ct. App. 2014). “’s will and sought a declaration of rights pursuant to RCW 11.84.020. Eaden argued that *441 Cal Sr.”
In Re the Est. of Little, 721 P.2d 950 (Wash. 1986). “[34] See RCW 11.84.020 and RCW 11.84.030. [35] See Henderson v.”
Beggs v. Dep't of Soc. & Health Servs., 171 Wash. 2d 69 (Wash. 2011). “RCW 11.84.020. She is deemed to have predeceased him.”
In Re Est. of Kissinger, 206 P.3d 665 (Wash. 2009). “" For purposes of the distribution of the estate, a person determined to be a slayer is deemed to have predeceased the decedent.”
Hoss v. Hoge, 166 Wash. 2d 120 (Wash. 2009). “RCW 11.84.020 states that “[n]o slayer shall in any way acquire any property or receive any benefit as the result of the death of the decedent.”
In re the Est. of Haviland, 301 P.3d 31 (Wash. 2013). “” RCW 11.84.020. An “abuser” is “any person who participates, either as a principal or an accessory before the fact, in the willful and unlawfiil financial exploitation of a vulnerable adult.”
Leavy v. Metro. Life Ins., 581 P.2d 167 (Wash. Ct. App. 1978). “RCW 11.84.020. A slayer is one who participates in the "wilful and unlawful killing" of another person.”
Armstrong v. Bray, 826 P.2d 706 (Wash. Ct. App. 1992). “RCW 11.84.020. The slayer shall be deemed to have predeceased the decedent as to property which would have passed from the decedent or his estate to the slayer under the statutes of descent and distribution or have been acquired by statutory right as surviving spouse or under…”
Est. of Kissinger v. Hoge, 173 P.3d 956 (Wash. Ct. App. 2007). “We are then left with the question of the degree to which Hoge's delusion prevented him from forming the intent to kill.”
Hoge v. Hoss, 142 Wash. App. 76 (Wash. Ct. App. 2007). “This factual determination is best left to the trial court and further psychiatric evidence.”
Cook v. Gisler, 582 P.2d 550 (Wash. Ct. App. 1978). “” *679 RCW 11.84.020 states: "Slayer not to benefit from death.”
Haviland v. Haviland, 251 P.3d 289 (Wash. Ct. App. 2011). “Specifically, RCW 11.84.020 provides: No slayer or abuser shall in any way acquire any property or receive any benefit as the result of the death of the decedent, but such property shall pass as provided in the sections following.”
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