Wash. Rev. Code » Title 19 · Chapter 19.36
Revised Code of Washington

Wash. Rev. Code § 19.36.010 (2026)

Contracts, etc., void unless in writing

✓ current as of May 2026
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In the following cases, specified in this section, any agreement, contract, and promise shall be void, unless such agreement, contract, or promise, or some note or memorandum thereof, be in writing, and signed by the party to be charged therewith, or by some person thereunto by him or her lawfully authorized, that is to say: (1) Every agreement that by its terms is not to be performed in one year from the making thereof; (2) every special promise to answer for the debt, default, or misdoings of another person; (3) every agreement, promise, or undertaking made upon consideration of marriage, except mutual promises to marry; (4) every special promise made by an executor or administrator to answer damages out of his or her own estate; (5) an agreement authorizing or employing an agent or broker to sell or purchase real estate for compensation or a commission.
[ 2011 c 336 s 540; 1905 c 58 s 1; RRS s 5825. Prior: Code 1881 s 2325; 1863 p 412 s 2; 1860 p 298 s 2; 1854 p 403 s 2.]
Notes of Decisions
Cited in 126 cases (7 in the last 5 years), 1953–2026 · leading case: House v. Erwin, 524 P.2d 911 (Wash. 1974).
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House v. Erwin, 524 P.2d 911 (Wash. 1974). · cites it 18× “Defendants contend the description is inadequate to comply with RCW 19.36.010. The contract is shown in the accompanying illustration.”
Lige Dickson Co. v. Union Oil Co. of California, 635 P.2d 103 (Wash. 1981). · cites it 6× “By so doing, we make no comment on the applicability of § 217A to defeat the raising of the statute of frauds as a defense under RCW 19.36.010. BRACHTENBACH, C.J., and STAFFORD, UTTER, DOLLIVER, WILLIAMS, and DIMMICK, JJ.”
Moss v. Vadman, 463 P.2d 159 (Wash. 1969). · cites it 6× “RCW 19.36.010(5). Reliance is placed on Carkonen v.”
Greaves v. Med. Imaging Sys., Inc., 879 P.2d 276 (Wash. 1994). · cites it 4× “The Washington statute of frauds, RCW 19.36.010, provides: In the following cases, specified in this section, any agreement, contract and promise shall be void, unless such agree- *396 merit, contract or promise, or some note or memorandum thereof, be in writing, and signed by…”
In re the Marriage of DewBerry, 115 Wash. App. 351 (Wash. Ct. App. 2003). · cites it 2× “Accordingly, this is a matter of first impression, and we address both the statute of frauds and Washington law concerning prenuptial agreements.”
Klinke v. Famous Recipe Fried Chicken, Inc., 616 P.2d 644 (Wash. 1980). · cites it 2× “" RCW 19.36.010. 4 The purpose of promissory estoppel is "to make a promise binding, under certain circumstances, without consideration in the usual sense of something bargained for and given in exchange.”
Firth v. Hefu Lu, 49 P.3d 117 (Wash. 2002). · cites it 3× “Although the general statute of frauds, RCW 19.36.010, differs from the real estate statute of frauds, the two share common theoretical underpinnings.”
Duckworth v. Langland, 988 P.2d 967 (Wash. Ct. App. 1998). · cites it 3× “RCW 19.36.010 states: In the following cases .”
Firth v. Lu, 49 P.3d 117 (Wash. 2002). · cites it 3× “Although the general statute of frauds, RCW 19.36.010, differs from the real estate statute of frauds, the two share common theoretical underpinnings.”
Lectus, Inc. v. Rainier Nat'l Bank, 647 P.2d 1001 (Wash. 1982). · cites it 3× “1-7, 1973) (hereafter § 217A) 1 and thus recognize promissory estoppel *586 as a theory of recovery notwithstanding the statute of frauds, RCW 19.36.010. 2 We decline to do so at this time.”
City of Tukwila v. Garrett, 196 P.3d 681 (Wash. 2008). · cites it 2× “See RCW 19.36.010. Contracts that have been terminated or extinguished cannot be extended without written agreement.”
Dowgialla v. Knevage, 294 P.2d 393 (Wash. 1956). · cites it 5× “The pertinent statutes provide, in part, as follows: RCW 19.36.010 [ cf. Rem. Rev. Stat., § 5825]: "In the following cases any agreement .”
Show all 126 citing cases →
— Wash. Rev. Code § 19.36.010(1) — 13 cases
Lige Dickson Co. v. Union Oil Co. of California, 635 P.2d 103 (Wash. 1981). “By so doing, we make no comment on the applicability of § 217A to defeat the raising of the statute of frauds as a defense under RCW 19.36.010. BRACHTENBACH, C.J., and STAFFORD, UTTER, DOLLIVER, WILLIAMS, and DIMMICK, JJ.”
Klinke v. Famous Recipe Fried Chicken, Inc., 616 P.2d 644 (Wash. 1980). “" RCW 19.36.010. 4 The purpose of promissory estoppel is "to make a promise binding, under certain circumstances, without consideration in the usual sense of something bargained for and given in exchange.”
Teratron Gen. v. Institutional Investors Trust, 569 P.2d 1198 (Wash. Ct. App. 1977).
Klinke v. Famous Recipe Fried Chicken, Inc., 600 P.2d 1034 (Wash. Ct. App. 1979).
Smith v. Twohy, 425 P.2d 12 (Wash. 1967).
— Wash. Rev. Code § 19.36.010(2) — 7 cases
Westar Funding, Inc. v. Sorrels, 239 P.3d 1109 (Wash. Ct. App. 2010).
Westar Funding, Inc. v. Sorrels, 157 Wash. App. 777 (Wash. Ct. App. 2010).
Sposari v. Matt Malaspina & Co., 388 P.2d 970 (Wash. 1964).
Smith v. Twohy, 425 P.2d 12 (Wash. 1967).
Soderberg Advert., Inc. v. Kent-Moore Corp., 524 P.2d 1355 (Wash. Ct. App. 1974).
— Wash. Rev. Code § 19.36.010(3) — 1 case
In re Lee L. Mackessy v. Richard Allinger (Wash. Ct. App. 2016).
— Wash. Rev. Code § 19.36.010(5) — 15 cases
Moss v. Vadman, 463 P.2d 159 (Wash. 1969). “RCW 19.36.010(5). Reliance is placed on Carkonen v.”
House v. Erwin, 524 P.2d 911 (Wash. 1974). “Defendants contend the description is inadequate to comply with RCW 19.36.010. The contract is shown in the accompanying illustration.”
Bell v. Hegewald, 628 P.2d 1305 (Wash. 1981).
Howell v. Inland Empire Paper Co., 624 P.2d 739 (Wash. Ct. App. 1981).
In Re Est. of Verbeek, 467 P.2d 178 (Wash. Ct. App. 1970).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.