Revised Code of Washington

Wash. Rev. Code § 19.100.180 (2026)

✓ current as of May 2026

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Without limiting the other provisions of this chapter, the following specific rights and prohibitions shall govern the relation between the franchisor or subfranchisor and the franchisees:

(1) The parties shall deal with each other in good faith.

(2) For the purposes of this chapter and without limiting its general application, it shall be an unfair or deceptive act or practice or an unfair method of competition and therefore unlawful and a violation of this chapter for any person to:

(a) Restrict or inhibit the right of the franchisees to join an association of franchisees.

(b) Require a franchisee to purchase or lease goods or services of the franchisor or from approved sources of supply unless and to the extent that the franchisor satisfies the burden of proving that such restrictive purchasing agreements are reasonably necessary for a lawful purpose justified on business grounds, and do not substantially affect competition: PROVIDED, That this provision shall not apply to the initial inventory of the franchise. In determining whether a requirement to purchase or lease goods or services constitutes an unfair or deceptive act or practice or an unfair method of competition the courts shall be guided by the decisions of the courts of the United States interpreting and applying the anti-trust laws of the United States.

(c) Discriminate between franchisees in the charges offered or made for royalties, goods, services, equipment, rentals, advertising services, or in any other business dealing, unless and to the extent that the franchisor satisfies the burden of proving that any classification of or discrimination between franchisees is: (i) Reasonable, (ii) based on franchises granted at materially different times and such discrimination is reasonably related to such difference in time, or is based on other proper and justifiable distinctions considering the purposes of this chapter, and (iii) is not arbitrary. However, nothing in (c) of this subsection precludes negotiation of the terms and conditions of a franchise at the initiative of the franchisees.

(d) Sell, rent, or offer to sell to a franchisee any product or service for more than a fair and reasonable price.

(e) Obtain money, goods, services, anything of value, or any other benefit from any other person with whom the franchisee does business on account of such business unless such benefit is disclosed to the franchisee.

(f) If the franchise provides that the franchisee has an exclusive territory, which exclusive territory shall be specified in the franchise agreement, for the franchisor or subfranchisor to compete with the franchisee in an exclusive territory or to grant competitive franchises in the exclusive territory area previously granted to another franchisee.

(g) Require franchisee to assent to a release, assignment, novation, or waiver which would relieve any person from liability imposed by this chapter, except as otherwise permitted by RCW 19.100.220.

(h) Impose on a franchisee by contract, rule, or regulation, whether written or oral, any standard of conduct unless the person so doing can sustain the burden of proving such to be reasonable and necessary.

(i) Refuse to renew a franchise without fairly compensating the franchisee for the fair market value, at the time of expiration of the franchise, of the franchisee's inventory, supplies, equipment, and furnishings purchased from the franchisor, and good will, exclusive of personalized materials which have no value to the franchisor, and inventory, supplies, equipment, and furnishings not reasonably required in the conduct of the franchise business: PROVIDED, That compensation need not be made to a franchisee for good will if (i) the franchisee has been given one year's notice of nonrenewal and (ii) the franchisor agrees in writing not to enforce any covenant which restrains the franchisee from competing with the franchisor: PROVIDED FURTHER, That a franchisor may offset against amounts owed to a franchisee under this subsection any amounts owed by such franchisee to the franchisor.

(j) Terminate a franchise prior to the expiration of its term except for good cause. Good cause shall include, without limitation, the failure of the franchisee to comply with lawful material provisions of the franchise or other agreement between the franchisor and the franchisee and to cure such default after being given written notice thereof and a reasonable opportunity, which in no event need be more than thirty days, to cure such default, or if such default cannot reasonably be cured within thirty days, the failure of the franchisee to initiate within thirty days substantial and continuing action to cure such default: PROVIDED, That after three willful and material breaches of the same term of the franchise agreement occurring within a twelve-month period, for which the franchisee has been given notice and an opportunity to cure as provided in this subsection, the franchisor may terminate the agreement upon any subsequent willful and material breach of the same term within the twelve-month period without providing notice or opportunity to cure: PROVIDED FURTHER, That a franchisor may terminate a franchise without giving prior notice or opportunity to cure a default if the franchisee: (i) Is adjudicated a bankrupt or insolvent; (ii) makes an assignment for the benefit of creditors or similar disposition of the assets of the franchise business; (iii) voluntarily abandons the franchise business; or (iv) is convicted of or pleads guilty or no contest to a charge of violating any law relating to the franchise business. Upon termination for good cause, the franchisor shall purchase from the franchisee at a fair market value at the time of termination, the franchisee's inventory and supplies, exclusive of (i) personalized materials which have no value to the franchisor; (ii) inventory and supplies not reasonably required in the conduct of the franchise business; and (iii), if the franchisee is to retain control of the premises of the franchise business, any inventory and supplies not purchased from the franchisor or on his or her express requirement: PROVIDED, That a franchisor may offset against amounts owed to a franchisee under this subsection any amounts owed by such franchisee to the franchisor.

[ 2011 c 336 s 562; 1991 c 226 s 11; 1980 c 63 s 1; 1973 1st ex.s. c 33 s 4; 1972 ex.s. c 116 s 10; 1971 ex.s. c 252 s 18.]

Notes of Decisions

Cited in 45 cases (7 in the last 5 years), 1979–2026 · leading case: Coast to Coast Stores, Inc. v. Gruschus, 667 P.2d 619 (Wash. 1983).

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Coast to Coast Stores, Inc. v. Gruschus, 667 P.2d 619 (Wash. 1983). · cites it 44× “The trial court therefore erred by requiring the franchisor to pay a fair market value for the inventory under RCW 19.100.180, and we accordingly reverse.”

Carlock v. Pillsbury Co., 719 F. Supp. 791 (D. Minnesota 1989). · cites it 11× “(the Washington plaintiffs) assert a claim for damages under the Washington Franchise Investment Protection Act (WFIPA), and specifically Wash.Rev. Code Ann. § 19.100.180. Defendants now move the Court for summary judgment on Count XX, arguing that plaintiffs have failed to…”

Corp v. Atl.-Richfield Co., 860 P.2d 1015 (Wash. 1993). · cites it 18× “The types of problems this "bill of rights" is intended to address have been described as follows: The franchisor normally occupies an overwhelmingly stronger bargaining position and drafts the franchise agreement so as to maximize his power to control the franchisee.”

Nelson v. Nat'l Fund Raising Consultants, Inc., 842 P.2d 473 (Wash. 1992). · cites it 10× “The trial court stated: The practice by NFRCI and DeShazers of marking up the wholesale price of products and supplies to NFRC/Washington and to plaintiffs Nelson by a percentage of food costs and requiring the plaintiffs, Nelson and NFRC/Washington, to purchase all products and…”

Nat'l Muffler Dealers Assn., Inc. v. United States, 440 U.S. 472 (1979). · cites it 2× “1978-1979); Franchise Investment Protection Act, Wash. Rev. Code § 19.100.180 (1976). [23] The Association is nonprofit, and the Government does not contend here that it engages in a regular business of a kind ordinarily carried on for profit, or that its income inures to…”

Baskin-Robbins Franchising LLC v. Alpenrose Dairy, Inc., 825 F.3d 28 (1st Cir. 2016). “Alpenrose later warned that it would otherwise be entitled to fair compensation under the Washington Franchise Investment Protection Act, see Wash. Rev. Code § 19.100.180 (2)(i). Baskin-Robbins responded that Alpen-rose had waited too long and was no longer entitled to renew the…”

Saleemi v. Doctor's Assocs., Inc., 292 P.3d 108 (Wash. 2013). · cites it 2× “Thus, this conduct violated RCW 19.100.180[(2)](c).” CP at 289-90. He also found that “[although there is some evidence to the contrary, this discrimination was not motivated by respondents’ religion, race or ancestry.”

Red Lion Hotels Franchising, Inc. v. MAK, LLC, 663 F.3d 1080 (9th Cir. 2011). · cites it 2× “(2) For the purposes of this chapter and without limiting its general application, it shall be an unfair or deceptive act or practice or an unfair method of competition and therefore unlawful and a violation of this chapter for any person to: (a-j) [listing prohibited acts,…”

Payless Car Rental Sys., Inc. v. Draayer, 716 P.2d 929 (Wash. Ct. App. 1986). · cites it 7× “(1) The commission of any unfair or deceptive acts or practices or unfair methods of competition prohibited by RCW 19.100.180 as now or hereafter amended shall constitute an unfair or deceptive act or practice under the provisions of chapter 19.”

Dep't of Labor & Indus. v. Lyons Enter., Inc., 374 P.3d 1097 (Wash. 2016). “2d 1015 (1993) (citing RCW 19.100.180; Coast to Coast, 100 Wn.2d at 150 ).”

JM Vidal, Inc. v. Texdis USA, Inc., 764 F. Supp. 2d 599 (S.D.N.Y. 2011). · cites it 2× “” Wash. Rev. Code § 19.100.180 (2)(g). Here, Section XXI of the Franchise Agreement, titled “Release of Prior Claims,” purports to release Defendants “from any and all claims relating to or arising under any franchise agreement or any other agreement between the parties executed…”

Monster Energy Co. v. City Beverages, LLC, 940 F.3d 1130 (9th Cir. 2019). “See Wash. Rev. Code § 19.100.180 (2)(j). Monster served an arbitration demand on Olympic Eagle and filed an action in the district court seeking to compel arbitration.”

Show all 45 citing cases →

— Wash. Rev. Code § 19.100.180(1) — 4 cases

Coast to Coast Stores, Inc. v. Gruschus, 667 P.2d 619 (Wash. 1983). “The trial court therefore erred by requiring the franchisor to pay a fair market value for the inventory under RCW 19.100.180, and we accordingly reverse.”

Carlock v. Pillsbury Co., 719 F. Supp. 791 (D. Minnesota 1989). “(the Washington plaintiffs) assert a claim for damages under the Washington Franchise Investment Protection Act (WFIPA), and specifically Wash.Rev. Code Ann. § 19.100.180. Defendants now move the Court for summary judgment on Count XX, arguing that plaintiffs have failed to…”

Corp v. Atl.-Richfield Co., 860 P.2d 1015 (Wash. 1993). “The types of problems this "bill of rights" is intended to address have been described as follows: The franchisor normally occupies an overwhelmingly stronger bargaining position and drafts the franchise agreement so as to maximize his power to control the franchisee.”

Payless Car Rental Sys., Inc. v. Draayer, 716 P.2d 929 (Wash. Ct. App. 1986). “(1) The commission of any unfair or deceptive acts or practices or unfair methods of competition prohibited by RCW 19.100.180 as now or hereafter amended shall constitute an unfair or deceptive act or practice under the provisions of chapter 19.”

— Wash. Rev. Code § 19.100.180(2) — 10 cases

Nelson v. Nat'l Fund Raising Consultants, Inc., 842 P.2d 473 (Wash. 1992). “The trial court stated: The practice by NFRCI and DeShazers of marking up the wholesale price of products and supplies to NFRC/Washington and to plaintiffs Nelson by a percentage of food costs and requiring the plaintiffs, Nelson and NFRC/Washington, to purchase all products and…”

Armstrong v. Taco Time Int'l, Inc., 635 P.2d 1114 (Wash. Ct. App. 1981).

— Wash. Rev. Code § 19.100.180(2)(D) — 1 case

Nelson v. Nat'l Fund Raising Consultants, 823 P.2d 1165 (Wash. Ct. App. 1992).

— Wash. Rev. Code § 19.100.180(2)(b) — 2 cases

Nelson v. Nat'l Fund Raising Consultants, Inc., 823 P.2d 1165 (Wash. Ct. App. 1992).

Nelson v. Nat'l Fund Raising Consultants, 823 P.2d 1165 (Wash. Ct. App. 1992).

— Wash. Rev. Code § 19.100.180(2)(c) — 5 cases

Gen. Aviation, Inc. v. The Cessna Aircraft Co., 13 F.3d 178 (6th Cir. 1993).

Armstrong v. Taco Time Int'l, Inc., 635 P.2d 1114 (Wash. Ct. App. 1981).

Chico's Pizza Franchises, Inc. v. Sisemore, 544 F. Supp. 248 (E.D. Wash. 1981).

Noble Roman's, Inc. v. Hattenhauer Distrib. Co., 307 F. Supp. 3d 907 (2018).

— Wash. Rev. Code § 19.100.180(2)(d) — 6 cases

BP West Coast Prods. LLC v. SKR Inc., 989 F. Supp. 2d 1109 (W.D. Wash. 2013).

Nelson v. Nat'l Fund Raising Consultants, Inc., 823 P.2d 1165 (Wash. Ct. App. 1992).

Money Mailer, LLC v. Brewer (Wash. 2019).

Nelson v. Nat'l Fund Raising Consultants, 823 P.2d 1165 (Wash. Ct. App. 1992).

— Wash. Rev. Code § 19.100.180(2)(e) — 1 case

— Wash. Rev. Code § 19.100.180(2)(f) — 2 cases

Nelson v. Nat'l Fund Raising Consultants, Inc., 823 P.2d 1165 (Wash. Ct. App. 1992).

Nelson v. Nat'l Fund Raising Consultants, 823 P.2d 1165 (Wash. Ct. App. 1992).

— Wash. Rev. Code § 19.100.180(2)(g) — 1 case

— Wash. Rev. Code § 19.100.180(2)(h) — 1 case

— Wash. Rev. Code § 19.100.180(2)(i) — 7 cases

Gen. Aviation, Inc. v. The Cessna Aircraft Co., 13 F.3d 178 (6th Cir. 1993).

Thompson v. Atl. Richfield Co., 663 F. Supp. 206 (W.D. Wash. 1986).

Atkins v. Chevron USA Inc., 672 F. Supp. 1373 (W.D. Wash. 1987).

Instructional Sys., Inc. v. Comput. Curriculum Corp., 826 F. Supp. 831 (D.N.J. 1993).

— Wash. Rev. Code § 19.100.180(2)(j) — 7 cases

Rutter v. BX of Tri-Cities, Inc., 806 P.2d 1266 (Wash. Ct. App. 1991).

Saleemi v. Doctor's Assocs., Inc., 269 P.3d 350 (Wash. Ct. App. 2012).

— Wash. Rev. Code § 19.100.180(J) — 1 case

Dunne Leases Cars & Trucks, Inc. v. Kenworth Truck Co., 466 A.2d 1153 (R.I. 1983).

— Wash. Rev. Code § 19.100.180(b) — 1 case

JTH Tax LLC v. Kelly (W.D. Wash. 2020).

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