Revised Code of Washington
Wash. Rev. Code § 11.84.150 (2026)
✓ current as of May 2026
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(1) A final judgment of conviction for conduct constituting financial exploitation against the decedent, including but not limited to theft, forgery, fraud, identity theft, robbery, burglary, or extortion, is conclusive for purposes of determining whether a person is an abuser under this section.
(2) In the absence of a criminal conviction, a superior court finding by clear, cogent, and convincing evidence that a person participated in conduct constituting financial exploitation against the decedent is conclusive for purposes of determining whether a person is an abuser under this section.
[ 2009 c 525 s 15.]
Notes of Decisions
Cited in 4
cases (1 in the last 5 years), 2011–2023 · leading case: In Re The Est. Of Richard D. Kolesar, 532 P.3d 170 (Wash. Ct. App. 2023).
In Re The Est. Of Richard D. Kolesar, 532 P.3d 170 (Wash. Ct. App. 2023). “RCW 11.84.150(2); .160(1). “Financial exploitation” is defined as (a) The use of deception, intimidation, or undue influence by a person or entity in a position of trust and confidence with a vulnerable adult to obtain or use the property, income, resources, or trust funds of…”
Haviland v. Haviland, 251 P.3d 289 (Wash. Ct. App. 2011). “RCW 11.84.150(2) also provides that a person is adjudicated as an abuser and thereby prohibited from benefiting from the vulnerable person’s will when “a superior court [finds] by clear, cogent, and convincing evidence that a person participated in conduct constituting financial…”
In Re Est. of Haviland, 251 P.3d 289 (Wash. Ct. App. 2011). “RCW 11.84.150(2) also provides that a person is adjudicated as an abuser and thereby prohibited from benefiting from the vulnerable person's will when a superior court [finds] by clear, cogent, and convincing evidence that a person participated in conduct constituting financial…”
In Re The Est. Of Curtis E. Carlson, David Wands, Dds, Resp v. Dona Seely, Dds, Pet (Wash. Ct. App. 2019). “Pursuant to RCW 11.84.150(2) and chapter 11.96A RCW, Dona Seely shall be and hereby is determined and declared to be an abuser under RCW 11.”
— Wash. Rev. Code § 11.84.150(2) — 4 cases
In Re The Est. Of Richard D. Kolesar, 532 P.3d 170 (Wash. Ct. App. 2023). “RCW 11.84.150(2); .160(1). “Financial exploitation” is defined as (a) The use of deception, intimidation, or undue influence by a person or entity in a position of trust and confidence with a vulnerable adult to obtain or use the property, income, resources, or trust funds of…”
Haviland v. Haviland, 251 P.3d 289 (Wash. Ct. App. 2011). “RCW 11.84.150(2) also provides that a person is adjudicated as an abuser and thereby prohibited from benefiting from the vulnerable person’s will when “a superior court [finds] by clear, cogent, and convincing evidence that a person participated in conduct constituting financial…”
In Re Est. of Haviland, 251 P.3d 289 (Wash. Ct. App. 2011). “RCW 11.84.150(2) also provides that a person is adjudicated as an abuser and thereby prohibited from benefiting from the vulnerable person's will when a superior court [finds] by clear, cogent, and convincing evidence that a person participated in conduct constituting financial…”
In Re The Est. Of Curtis E. Carlson, David Wands, Dds, Resp v. Dona Seely, Dds, Pet (Wash. Ct. App. 2019). “Pursuant to RCW 11.84.150(2) and chapter 11.96A RCW, Dona Seely shall be and hereby is determined and declared to be an abuser under RCW 11.”
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