Wash. Rev. Code » Title 19 · Chapter 19.100
Revised Code of Washington

Wash. Rev. Code § 19.100.170 (2026)

Violations

✓ current as of May 2026
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It is unlawful for any person in connection with the offer, sale, or purchase of any franchise or subfranchise in this state directly or indirectly:
(1) To make any untrue statement of a material fact in any application, notice, or report filed with the director under this law or willfully to omit to state in any application, notice or report, any material fact which is required to be stated therein or fails to notify the director of any material change as required by RCW 19.100.070(3).
(2) To sell or offer to sell by means of any written or oral communication which includes an untrue statement of a material fact or omits to state a material fact necessary in order to make the statements made in light of the circumstances under which they were made not misleading.
(3) To employ any device, scheme, or artifice to defraud.
(4) To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person.
(5) To violate any order of the director.
[ 1991 c 226 s 10; 1971 ex.s. c 252 s 17.]
Notes of Decisions
Cited in 16 cases, 1979–2020 · leading case: Morris v. Int'l Yogurt Co., 729 P.2d 33 (Wash. 1986).
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Morris v. Int'l Yogurt Co., 729 P.2d 33 (Wash. 1986). · cites it 9× “RCW 19.100.170 provides, in part: It is unlawful for any person in connection with the offer, sale, or purchase of any franchise directly or indirectly: (2) To sell or offer to sell a franchise in this state by *322 means of any written or oral communication which includes an…”
Kirkham v. Smith, 23 P.3d 10 (Wash. Ct. App. 2001). · cites it 2× “NOTES [1] RCW 19.100.170 (FIPA) states in part: "It is unlawful for any person in connection with the offer, sale, or purchase of any franchise or subfranchise in this state directly or indirectly: ".”
Kirkham v. Smith, 106 Wash. App. 177 (Wash. Ct. App. 2001). · cites it 2× “RCW 19.100.170 (PIPA) states in part: “It is unlawful for any person in connection with the offer, sale, or purchase of any franchise or subfranchise in this state directly or indirectly: “(2) Tb sell or offer to sell by means of any written or oral communication which includes…”
Allison v. Medicab Int'l, Inc., 597 P.2d 380 (Wash. 1979). · cites it 2× “RCW 19.100.170 makes it unlawful for any person to make any untrue statement of a material fact in connection with the sale of a franchise.”
JM Vidal, Inc. v. Texdis USA, Inc., 764 F. Supp. 2d 599 (S.D.N.Y. 2011). · cites it 2× “Wash. Rev. Code § 19.100.170 (2)-(4). In order to prove a WFIPA fraud claim, the plaintiff must show justifiable reliance.”
Camac v. Dontos, 390 S.W.3d 398 (Tex. App. 2012). “926 (West 2011), and the Washington Franchise Investment Protection Act, Wash. Rev.Code Ann. § 19.100.170 (West 2008).”
Morris v. Int'l Yogurt Co., 703 P.2d 318 (Wash. Ct. App. 1985). · cites it 4× “[2] RCW 19.100.170 states in pertinent part: "It is unlawful for any person in connection with the offer, sale, or purchase of any franchise directly or indirectly: ".”
Corp v. Atl.-Richfield Co., 860 P.2d 1015 (Wash. 1993). “170(2); and (3) ARCO constructively terminated or refused to renew the minimarket leases of those who declined to accept am/pm franchises by deliberately failing to perform its obligations under the leases, in violation of RCW 19.100-.180(2)(i) and (j).”
Rutter v. BX of Tri-Cities, Inc., 806 P.2d 1266 (Wash. Ct. App. 1991). “RCW 19.100.170 and .180 designate certain practices in connection with the sale, execution, renewal or termination of franchise agreements as unlawful acts.”
Payless Car Rental Sys., Inc. v. Draayer, 716 P.2d 929 (Wash. Ct. App. 1986). “In the case of a violation of RCW 19.100.170 rescission is not available to the plaintiff if the defendant proves that the plaintiff knew the facts concerning the untruth or omission or that the defendant exercised reasonable care and did not know or if he had exercised…”
Something Sweet, LLC v. Nick-N-Willy's Franchise Co., 237 P.3d 923 (Wash. Ct. App. 2010). · cites it 3× “RCW 19.100.170. ¶8 In Morris v. International Yogurt Co.”
Velicer v. Falconhead Capital LLC (W.D. Wash. 2020). · cites it 9× “8 Plaintiffs argue that FIPA prohibits the dismissal of their FIPA claims brought 9 under RCW 19.100.170 based on the 2016 releases.”
Show all 16 citing cases →
— Wash. Rev. Code § 19.100.170(2) — 11 cases
Morris v. Int'l Yogurt Co., 729 P.2d 33 (Wash. 1986). “RCW 19.100.170 provides, in part: It is unlawful for any person in connection with the offer, sale, or purchase of any franchise directly or indirectly: (2) To sell or offer to sell a franchise in this state by *322 means of any written or oral communication which includes an…”
Kirkham v. Smith, 23 P.3d 10 (Wash. Ct. App. 2001). “NOTES [1] RCW 19.100.170 (FIPA) states in part: "It is unlawful for any person in connection with the offer, sale, or purchase of any franchise or subfranchise in this state directly or indirectly: ".”
Kirkham v. Smith, 106 Wash. App. 177 (Wash. Ct. App. 2001). “RCW 19.100.170 (PIPA) states in part: “It is unlawful for any person in connection with the offer, sale, or purchase of any franchise or subfranchise in this state directly or indirectly: “(2) Tb sell or offer to sell by means of any written or oral communication which includes…”
Corp v. Atl.-Richfield Co., 860 P.2d 1015 (Wash. 1993). “170(2); and (3) ARCO constructively terminated or refused to renew the minimarket leases of those who declined to accept am/pm franchises by deliberately failing to perform its obligations under the leases, in violation of RCW 19.100-.180(2)(i) and (j).”
Morris v. Int'l Yogurt Co., 703 P.2d 318 (Wash. Ct. App. 1985). “[2] RCW 19.100.170 states in pertinent part: "It is unlawful for any person in connection with the offer, sale, or purchase of any franchise directly or indirectly: ".”
— Wash. Rev. Code § 19.100.170(3) — 1 case
JM Vidal, Inc. v. Texdis USA, Inc., 764 F. Supp. 2d 599 (S.D.N.Y. 2011). “Wash. Rev. Code § 19.100.170 (2)-(4). In order to prove a WFIPA fraud claim, the plaintiff must show justifiable reliance.”
— Wash. Rev. Code § 19.100.170(4) — 1 case
Velicer v. Falconhead Capital LLC (W.D. Wash. 2020). “8 Plaintiffs argue that FIPA prohibits the dismissal of their FIPA claims brought 9 under RCW 19.100.170 based on the 2016 releases.”
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