Revised Code of Washington

Wash. Rev. Code § 19.36.020 (2026)

Deeds, etc., in trust for grantor void as to creditors

✓ current as of May 2026

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That all deeds of gift, all conveyances, and all transfers or assignments, verbal or written, of goods, chattels or things in action, made in trust for the use of the person making the same, shall be void as against the existing or subsequent creditors of such person. For purposes of this section, a person shall not be treated as having made a disposition in trust for the use of that person by reason of a lapse of a power of withdrawal over the income or corpus of a trust created by another person. For this purpose, notification to the trustee of the trust of an intent not to exercise the power of withdrawal shall not be treated as a release of the power of withdrawal, but shall be treated as a lapse of the power.

[ 2006 c 360 s 14; Code 1881 s 2324; RRS s 5824. Prior: 1863 p 412 s 1; 1860 p 298 s 1; 1854 p 403 s 1.]

Notes:

Clarification of laws—Enforceability of act—Severability—2006 c 360: See notes following RCW 11.108.070.

Notes of Decisions

Cited in 5 cases, 1986–2016 · leading case: Waldron v. Huber (In re Huber), 493 B.R. 798 (Bankr. W.D. Wash. 2013).

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Waldron v. Huber (In re Huber), 493 B.R. 798 (Bankr. W.D. Wash. 2013). · cites it 10× “110, but Washington does not, see RCW 19.36.020. As such, the parties agree there is a conflict in the laws of the two states, and the Court must look to choice of law rules for guidance.”

Rigby v. Mastro (In re Mastro), 465 B.R. 576 (Bankr. W.D. Wash. 2011). · cites it 6× “In addition, Washington law provides that “all deeds of gift, all conveyances, and all transfers or assignments, verbal or written, of goods, chattels or things in action, made in trust for the use of the person making the same, shall be void as against the existing or…”

Wiswall v. Wallaert (In Re Wallaert), 149 B.R. 665 (Bankr. W.D. Wash. 1992). “RCW 19.36.020: 5 . Section 101(54): there are two subsections 101(54), the other defining “stock broker”: see footnote 4 to Barnhill v.”

Est. of Paxton v. Comm'r, 86 T.C. 785 (1986). · cites it 6× “That all deeds of gift, all conveyances, and all transfers or assignments, verbal or written, of goods, chattels or things in action, made in trust for the use of the person making the same, shall be void as against the existing or subsequent creditors of such person.”

Gary Waddoups v. Nationwide Life Ins. Co. (Wash. Ct. App. 2016). · cites it 2× “n applying subsection ( 1) of this section: ! i (e) A trust for the decedent's use of which the decedent is the grantor is subject to the decedent's liabilities, claims, estate taxes, and I administration expenses as described in subsection ( 1) of this section, to the same…”

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