Wash. Rev. Code » Title 19 · Chapter 19.52
Revised Code of Washington

Wash. Rev. Code § 19.52.080 (2026)

Defense of usury or maintaining action thereon prohibited if transaction primarily agricultural, commercial, investment, or business—Exception

✓ current as of May 2026
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Profit and nonprofit corporations, Massachusetts trusts, associations, trusts, general partnerships, joint ventures, limited partnerships, and governments and governmental subdivisions, agencies, or instrumentalities may not plead the defense of usury nor maintain any action thereon or therefor, and persons may not plead the defense of usury nor maintain any action thereon or therefor if the transaction was primarily for agricultural, commercial, investment, or business purposes: PROVIDED, HOWEVER, That this section shall not apply to a consumer transaction of any amount.
Consumer transactions, as used in this section, shall mean transactions primarily for personal, family, or household purposes.
[ 1981 c 78 s 2; 1975 1st ex.s. c 180 s 1; 1970 ex.s. c 97 s 2; 1969 ex.s. c 142 s 1.]

Notes:

Severability—1981 c 78: See note following RCW 19.52.020.
Notes of Decisions
Cited in 36 cases (6 in the last 5 years), 1970–2026 · leading case: Paulman v. Filtercorp, Inc., 899 P.2d 1259 (Wash. 1995).
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Paulman v. Filtercorp, Inc., 899 P.2d 1259 (Wash. 1995). · cites it 64× “The Court of Appeals reversed because it concluded that under RCW 19.52.080 a corporate debtor who takes a loan for a business purpose is not entitled to raise the defense of usury.”
Brown v. Giger, 757 P.2d 523 (Wash. 1988). · cites it 28× “Replying and answering, plaintiffs contended that their loan with Giger was not usurious because it was exempt from the usury laws under the "business purpose" exemption in RCW 19.52.080. Plaintiffs also asserted that Giger's claim under the Consumer Protection Act is precluded…”
Thweatt v. Hommel, 834 P.2d 1058 (Wash. Ct. App. 1992). · cites it 10× “Because we conclude that the loan qualified for the business purpose exemption provided by RCW 19.52.080, we reverse and remand for entry of judgment in favor of Hommel on his counterclaim for judicial foreclosure of the deed of trust securing the note.”
Aetna Fin. Co. v. Darwin, 691 P.2d 581 (Wash. Ct. App. 1984). · cites it 12× “2 RCW 19.52.080. Aetna wished to limit its loans to those that would qualify for the exemption, and therefore would only make loans that exceeded $50,000.”
Pacesetter Real Est., Inc. v. Fasules, 767 P.2d 961 (Wash. Ct. App. 1989). · cites it 5× “Fasules contends the loans to Pacesetter were primarily for commercial or business purposes as opposed to personal, family, or household purposes, within the meaning of RCW 19.52.080. 7 This statute provides an exception to the usury defense when the purposes of the loan are…”
Sparkman & McLean Co. v. Govan Inv. Trust, 478 P.2d 232 (Wash. 1970). · cites it 8× “This addition is codified as RCW 19.52.080. The legislature further amended this statute by enacting chapter 97, section 2, Laws of 1970, Ex.”
Marashi v. Lannen, 780 P.2d 1341 (Wash. Ct. App. 1989). · cites it 5× “The Lannens do not contend the loan to the Mara-shis was not usurious on its face, but claim RCW 19.52.080 precludes the Marashis from maintaining their action for usury.”
Castronuevo v. Gen. Acceptance Corp., 905 P.2d 387 (Wash. Ct. App. 1995). · cites it 6× “We affirm the judgment in favor of GAC, but on the ground that the loan at issue was a business loan and therefore fell within the scope of RCW 19.52.080, which prohibits a person from pleading the defense of usury or maintaining an action for usury if the transaction was for a…”
McGovern v. Smith, 801 P.2d 250 (Wash. Ct. App. 1991). · cites it 5× “The court ruled that Smith had not met his burden of proof that the loan fell within the business purpose exemption of RCW 19.52.080 as to the Marinos, so that issue proceeded to a bench trial.”
Jansen v. Nu-West, Inc., 6 P.3d 98 (Wash. Ct. App. 2000). · cites it 5× “Usury — A Question of Fact or Law? Nu-West further argues that the usury issue should never have gone to the jury because the primary purpose of a loan, and therefore the applicability of RCW 19.”
Stevens v. Sec. Pac. Mortg. Corp., 768 P.2d 1007 (Wash. Ct. App. 1989). · cites it 3× “Usurious on Its Face Stevens first argues that the loan was usurious on its face, and thus the burden is on the lender to prove that the transaction was exempt under RCW 19.52.080. RCW 19.52.020(1) sets the maximum legal rate of interest.”
Jansen v. Nu-West, Inc., 6 P.3d 98 (Wash. Ct. App. 2000). · cites it 5× “And while a motion for reconsideration (CR 59) might have resurrected the issue, none was filed here. USURY—A QUESTION OF FACT OR LAW? Nu-West further argues that the usury issue should never have gone to the jury because the primary purpose of a loan and therefore the…”
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