Revised Code of Washington
Wash. Rev. Code § 13.34.105 (2026)
✓ current as of May 2026
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(1) Unless otherwise directed by the court, the duties of the guardian ad litem for a child subject to a proceeding under this chapter, including an attorney specifically appointed by the court to serve as a guardian ad litem, include but are not limited to the following:
(a) To investigate, collect relevant information about the child's situation, and report to the court factual information regarding the best interests of the child;
(b) To meet with, interview, or observe the child, depending on the child's age and developmental status, and report to the court any views or positions expressed by the child on issues pending before the court;
(c) To monitor all court orders for compliance and to bring to the court's attention any change in circumstances that may require a modification of the court's order;
(d) To report to the court information on the legal status of a child's membership in any Indian tribe or band;
(e) Court-appointed special advocates and guardians ad litem may make recommendations based upon an independent investigation regarding the best interests of the child, which the court may consider and weigh in conjunction with the recommendations of all of the parties;
(f) To represent and be an advocate for the best interests of the child;
(g) To inform the child, if the child is twelve years old or older, of his or her right to request counsel and to ask the child whether he or she wishes to have counsel, pursuant to *RCW 13.34.100(6). The guardian ad litem shall report to the court that the child was notified of this right and indicate the child's position regarding appointment of counsel. The guardian ad litem shall report to the court his or her independent recommendation as to whether appointment of counsel is in the best interest of the child; and
(h) In the case of an Indian child as defined in RCW 13.38.040, know, understand, and advocate the best interests of the Indian child.
(2) A guardian ad litem shall be deemed an officer of the court for the purpose of immunity from civil liability.
(3) Except for information or records specified in RCW 13.50.100(7), the guardian ad litem shall have access to all information available to the state or agency on the case. Upon presentation of the order of appointment by the guardian ad litem, any agency, hospital, school organization, division or department of the state, doctor, nurse, or other health care provider, psychologist, psychiatrist, police department, or mental health clinic shall permit the guardian ad litem to inspect and copy any records relating to the child or children involved in the case, without the consent of the parent or guardian of the child, or of the child if the child is under the age of thirteen years, unless such access is otherwise specifically prohibited by law.
(4) A guardian ad litem may release confidential information, records, and reports to the office of the family and children's ombuds for the purposes of carrying out its duties under chapter 43.06A RCW.
(5) The guardian ad litem shall release case information in accordance with the provisions of RCW 13.50.100.
[ 2013 c 23 s 5; 2011 c 309 s 26; 2010 c 180 s 3; 2008 c 267 s 13; 2000 c 124 s 4; 1999 c 390 s 2; 1993 c 241 s 3.]
Notes:
Findings—2010 c 180: See note following RCW 13.34.100.
Conflict with federal requirements—1993 c 241: See note following RCW 13.34.030.
Notes of Decisions
Cited in 29
cases (3 in the last 5 years), 1994–2024 · leading case: In re the Welfare of T.B., 150 Wash. App. 599 (Wash. Ct. App. 2009).
In re the Welfare of T.B., 150 Wash. App. 599 (Wash. Ct. App. 2009). “Former RCW 13.34.105 provides: (1) Unless otherwise directed by the court, the duties of the guardian ad litem include but are not limited to the following: (a) To investigate, collect relevant information about the child’s situation, and report to the court factual information…”
In re Dependency of E.H., 427 P.3d 587 (Wash. 2018). “at 10; see RCW 13.34.105(1)(b). However, the position ofthe State and the CASA,that termination is in E.”
In Re Welfare of TB, 209 P.3d 497 (Wash. Ct. App. 2009). “Former RCW 13.34.105 provides: (1) Unless otherwise directed by the court, the duties of the guardian ad litem include but are not limited to the following: (a) To investigate, collect relevant information about the child's situation, and report to the court factual information…”
Kelley v. Pierce Cnty., 319 P.3d 74 (Wash. Ct. App. 2014). “030(10) (2011); RCW 13.34.105(1). Specifically, RCW 13.34.”
In re the Welfare of B.D.F., 126 Wash. App. 562 (Wash. Ct. App. 2005). “Further, RCW 13.34.105(1) also endorses the GAL’s standing and duty to advocate for children.”
State v. Aradon (In re A.E.T.H.), 446 P.3d 667 (Wash. Ct. App. 2019). “Sections (e) and (f) include references to the "best interests of the child" and state: (e) Court-appointed special advocates and guardians ad litem may make recommendations based upon an independent investigation regarding the best interests of the child, which the court may…”
In Re Jn, 95 P.3d 414 (Wash. Ct. App. 2004). “cites to the duties of a GAL set forth in RCW 13.34.105. This statute requires a GAL to "investigate, collect relevant information about the child's situation, and report to the court factual information regarding the best interests of the child.”
In re the Welfare of J.N., 123 Wash. App. 564 (Wash. Ct. App. 2004). “cites to the duties of a GAL set forth in RCW 13.34.105. This statute requires a GAL to “investigate, collect relevant information about the child’s situation, and report to the court factual information regarding the best interests of the child.”
Dep't of Soc. & Health Servs. v. Luak, 271 P.3d 234 (Wash. 2012). “Among other things, the GAL is required to advocate for the child’s interests and is required to inform the court of any “views or positions expressed by the child on issues pending before the court” and to “represent and be an advocate for the best interests of the child.”
In re Dependency of E.M., 484 P.3d 461 (Wash. 2021). “See RCW 13.34.105. 10 In re Dependency of E.M.”
In Re the Welfare of S.V.B., 880 P.2d 80 (Wash. Ct. App. 1994). “100; see RCW 13.34.105. Clearly, it also permits the juvenile court to consider the guardian’s report.”
In Re Welfare of Bdf, 109 P.3d 464 (Wash. Ct. App. 2005). “Further, RCW 13.34.105(1) also endorses the GAL's standing and duty to advocate for children.”
— Wash. Rev. Code § 13.34.105(1) — 12 cases
In re the Welfare of T.B., 150 Wash. App. 599 (Wash. Ct. App. 2009). “Former RCW 13.34.105 provides: (1) Unless otherwise directed by the court, the duties of the guardian ad litem include but are not limited to the following: (a) To investigate, collect relevant information about the child’s situation, and report to the court factual information…”
In Re Welfare of TB, 209 P.3d 497 (Wash. Ct. App. 2009). “Former RCW 13.34.105 provides: (1) Unless otherwise directed by the court, the duties of the guardian ad litem include but are not limited to the following: (a) To investigate, collect relevant information about the child's situation, and report to the court factual information…”
State v. Aradon (In re A.E.T.H.), 446 P.3d 667 (Wash. Ct. App. 2019). “Sections (e) and (f) include references to the "best interests of the child" and state: (e) Court-appointed special advocates and guardians ad litem may make recommendations based upon an independent investigation regarding the best interests of the child, which the court may…”
In re the Welfare of B.D.F., 126 Wash. App. 562 (Wash. Ct. App. 2005). “Further, RCW 13.34.105(1) also endorses the GAL’s standing and duty to advocate for children.”
Kelley v. Pierce Cnty., 319 P.3d 74 (Wash. Ct. App. 2014). “030(10) (2011); RCW 13.34.105(1). Specifically, RCW 13.34.”
— Wash. Rev. Code § 13.34.105(1)(a) — 6 cases
In Re Jn, 95 P.3d 414 (Wash. Ct. App. 2004). “cites to the duties of a GAL set forth in RCW 13.34.105. This statute requires a GAL to "investigate, collect relevant information about the child's situation, and report to the court factual information regarding the best interests of the child.”
Christopher Woodward v. Jessie Thomas (Wash. Ct. App. 2020).
Hartman v. State of Washington Dep't of Child. Youth & Families (W.D. Wash. 2024).
In Re The Dependency Of D.a.s., 2/22/02, Dshs v. Leona Lee (Wash. Ct. App. 2017).
In Re The Dependency Of: L.j., Dob: 12/10/13 Tijan Sumbundu v. Dshs (Wash. Ct. App. 2018).
— Wash. Rev. Code § 13.34.105(1)(b) — 4 cases
In re Dependency of E.H., 427 P.3d 587 (Wash. 2018). “at 10; see RCW 13.34.105(1)(b). However, the position ofthe State and the CASA,that termination is in E.”
Dep Of Ab., Mattie Macarthur v. Dshs State Of Washington (Wash. Ct. App. 2017).
In Re The Dependency Of S.k-p., A Minor Child (Wash. Ct. App. 2017).
In the Matter of the Parental Rights to: N.S.N. (Wash. Ct. App. 2019).
— Wash. Rev. Code § 13.34.105(1)(d) — 1 case
In Re Welfare of TB, 209 P.3d 497 (Wash. Ct. App. 2009). “Former RCW 13.34.105 provides: (1) Unless otherwise directed by the court, the duties of the guardian ad litem include but are not limited to the following: (a) To investigate, collect relevant information about the child's situation, and report to the court factual information…”
— Wash. Rev. Code § 13.34.105(1)(e) — 4 cases
In Re Welfare of TB, 209 P.3d 497 (Wash. Ct. App. 2009). “Former RCW 13.34.105 provides: (1) Unless otherwise directed by the court, the duties of the guardian ad litem include but are not limited to the following: (a) To investigate, collect relevant information about the child's situation, and report to the court factual information…”
State v. Aradon (In re A.E.T.H.), 446 P.3d 667 (Wash. Ct. App. 2019). “Sections (e) and (f) include references to the "best interests of the child" and state: (e) Court-appointed special advocates and guardians ad litem may make recommendations based upon an independent investigation regarding the best interests of the child, which the court may…”
In Re Welfare of Bdf, 109 P.3d 464 (Wash. Ct. App. 2005). “Further, RCW 13.34.105(1) also endorses the GAL's standing and duty to advocate for children.”
Dependency Of A.e.t.h., Dob: 2/24/13 (Wash. Ct. App. 2019).
— Wash. Rev. Code § 13.34.105(1)(f) — 2 cases
In re Dependency of E.H., 427 P.3d 587 (Wash. 2018). “at 10; see RCW 13.34.105(1)(b). However, the position ofthe State and the CASA,that termination is in E.”
Dependency Of P.s.f. Atiba Fleming v. Dshs (Wash. Ct. App. 2013).
— Wash. Rev. Code § 13.34.105(1)(g) — 1 case
In Re The Dependency Of D.a.s., 2/22/02, Dshs v. Leona Lee (Wash. Ct. App. 2017).
— Wash. Rev. Code § 13.34.105(2) — 5 cases
Kelley v. Pierce Cnty., 319 P.3d 74 (Wash. Ct. App. 2014). “030(10) (2011); RCW 13.34.105(1). Specifically, RCW 13.34.”
In re the Termination of: J.E.L.D. (Wash. Ct. App. 2016).
Hartman v. State of Washington Dep't of Child. Youth & Families (W.D. Wash. 2024).
In re the Welfare of: M.P. (Wash. Ct. App. 2015).
In re the Welfare of: M.P. (Wash. Ct. App. 2015).
— Wash. Rev. Code § 13.34.105(b) — 1 case
Dep Of E.j. M., Julia Morgan v. Dshs (Wash. Ct. App. 2020).
— Wash. Rev. Code § 13.34.105(l)(a) — 1 case
In re the Welfare of J.N., 123 Wash. App. 564 (Wash. Ct. App. 2004). “cites to the duties of a GAL set forth in RCW 13.34.105. This statute requires a GAL to “investigate, collect relevant information about the child’s situation, and report to the court factual information regarding the best interests of the child.”
— Wash. Rev. Code § 13.34.105(l)(b) — 2 cases
Dep't of Soc. & Health Servs. v. Luak, 271 P.3d 234 (Wash. 2012). “Among other things, the GAL is required to advocate for the child’s interests and is required to inform the court of any “views or positions expressed by the child on issues pending before the court” and to “represent and be an advocate for the best interests of the child.”
In re Dependency of E.H., 427 P.3d 587 (Wash. 2018). “at 10; see RCW 13.34.105(1)(b). However, the position ofthe State and the CASA,that termination is in E.”
— Wash. Rev. Code § 13.34.105(l)(d) — 1 case
In re the Welfare of T.B., 150 Wash. App. 599 (Wash. Ct. App. 2009). “Former RCW 13.34.105 provides: (1) Unless otherwise directed by the court, the duties of the guardian ad litem include but are not limited to the following: (a) To investigate, collect relevant information about the child’s situation, and report to the court factual information…”
— Wash. Rev. Code § 13.34.105(l)(e) — 2 cases
In re the Welfare of T.B., 150 Wash. App. 599 (Wash. Ct. App. 2009). “Former RCW 13.34.105 provides: (1) Unless otherwise directed by the court, the duties of the guardian ad litem include but are not limited to the following: (a) To investigate, collect relevant information about the child’s situation, and report to the court factual information…”
In re the Welfare of B.D.F., 126 Wash. App. 562 (Wash. Ct. App. 2005). “Further, RCW 13.34.105(1) also endorses the GAL’s standing and duty to advocate for children.”
— Wash. Rev. Code § 13.34.105(l)(f) — 1 case
In re Dependency of E.H., 427 P.3d 587 (Wash. 2018). “at 10; see RCW 13.34.105(1)(b). However, the position ofthe State and the CASA,that termination is in E.”
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