Wash. Rev. Code » Title 18 · Chapter 18.86
Revised Code of Washington

Wash. Rev. Code § 18.86.110 (2026)

Application

✓ current as of May 2026
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The duties under this chapter are statutory duties and not fiduciary duties. This chapter supersedes the fiduciary duties of an agent to a principal under the common law. The common law continues to apply to the parties in all other respects. This chapter does not affect the duties of a broker while engaging in the authorized or unauthorized practice of law as determined by the courts of this state. This chapter shall be construed broadly.
[ 2013 c 58 s 12; 1996 c 179 s 11.]
Notes of Decisions
Cited in 9 cases (1 in the last 5 years), 2009–2021 · leading case: Jackowski v. Borchelt, 278 P.3d 1100 (Wash. 2012).
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Jackowski v. Borchelt, 278 P.3d 1100 (Wash. 2012). · cites it 3× “The first provision, RCW 18.86.110, provides that chapter 18.86 RCW “supersedes only the duties of the parties under the common law, including fiduciary duties of an agent to a principal, to the extent inconsistent with this chapter.”
Boguch v. Landover Corp., 224 P.3d 795 (Wash. Ct. App. 2009). “In addition, pursuant to RCW 18.86.110, a real estate agent "retains common law duties" owed to clients.”
Boguch v. Landover Corp., 153 Wash. App. 595 (Wash. Ct. App. 2009). “In addition, pursuant to RCW 18.86.110, a real estate agent “retains common law duties” owed to clients.”
Jackowski v. Borchelt, 151 Wash. App. 1 (Wash. Ct. App. 2009). “RCW 18.86.110. For clarity, we reiterate that chapter 18.”
Jackowski v. Borchelt, 209 P.3d 514 (Wash. Ct. App. 2009). · cites it 2× “¶ 26 The Jackowskis correctly note that RCW 18.86.110 specifically retains common law duties, only superseding them where and to the extent that they are inconsistent with the statute.”
Lincoln & Leslie Beauregard, Appellants/cross-respondents v. Anna Riley, Respondent/cross-appellant (Wash. Ct. App. 2019). · cites it 3× “" In 2013, the legislature amended RCW 18.86.110 in light of the Supreme Court's holding in Jackowski v.”
Richard Nau, V Nancy K. Vogel As Tr. For Mark O Vogel (Wash. Ct. App. 2021). · cites it 2× “030(1)(a), which requires a real estate agent to “exercise reasonable skill and care.”
Montecito Est., LLC v. Douglas Joseph Himsl (Wash. Ct. App. 2013). “See RCW 18.86.110. Therefore, common law tort causes of action remain the vehicle through which a party may recover for a breach of statutory duties set forth in chapter 18.”
Lincoln & Judith David, Appellant's v. Richard Nord (Wash. Ct. App. 2014). “030, which defines a broker's duties, are inapplicable because RCW 18.86.110 specifically excludes the unauthorized practice of law.”
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