Wash. Rev. Code » Title 2 · Chapter 2.28
Revised Code of Washington

Wash. Rev. Code § 2.28.010 (2026)

Powers of courts in conduct of judicial proceedings

✓ current as of May 2026
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Every court of justice has power—(1) To preserve and enforce order in its immediate presence. (2) To enforce order in the proceedings before it, or before a person or body empowered to conduct a judicial investigation under its authority. (3) To provide for the orderly conduct of proceedings before it or its officers. (4) To compel obedience to its judgments, decrees, orders and process, and to the orders of a judge out of court, in an action, suit or proceeding pending therein. (5) To control, in furtherance of justice, the conduct of its ministerial officers, and of all other persons in any manner connected with a judicial proceeding before it, in every matter appertaining thereto. (6) To compel the attendance of persons to testify in an action, suit or proceeding therein, in the cases and manner provided by law. (7) To administer oaths in an action, suit or proceeding pending therein, and in all other cases where it may be necessary in the exercise of its powers or the performance of its duties.
[ 1955 c 38 s 12; 1909 c 124 s 2; RRS s 85.]

Notes:

Compelling attendance of witnesses: Chapter 5.56 RCW.
Oaths, who may administer: RCW 5.28.010.
Notes of Decisions
Cited in 56 cases (10 in the last 5 years), 1960–2026 · leading case: State v. Lormor, 257 P.3d 624 (Wash. 2011).
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State v. Lormor, 257 P.3d 624 (Wash. 2011). · cites it 2× “In addition to its inherent authority, the trial court, under RCW 2.28.010, 4 has the power to preserve and *94 enforce order in the courtroom and to provide for the orderly conduct of its proceedings.”
State v. SH, 8 P.3d 1058 (Wash. Ct. App. 2000). · cites it 3× “In a written order, the judge denied PDA's motion for reconsideration, citing RCW 2.28.010 and RCW 2.28.150. PDA appeals.”
State v. S.H., 102 Wash. App. 468 (Wash. Ct. App. 2000). · cites it 3× “In a written order, the judge denied PDA’s motion for reconsideration, citing RCW 2.28.010 and RCW 2.28.150. PDA appeals.”
State v. Smith, 334 P.3d 1049 (Wash. 2014). “2d at 93-94 (applying RCW 2.28.010). |21 The court need not reach this step if the answer to the first question is negative.”
Yurtis v. Phipps, 143 Wash. App. 680 (Wash. Ct. App. 2008). “RCW 2.28.010(3); In re Marriage of Lilly, 75 Wn.”
State v. Slert, 334 P.3d 1088 (Wash. 2014). “3d 624 (2011) (citing RCW 2.28.010). This includes the authority, when appropriate, to seal the courtroom or take matters into chambers for discussion with counsel.”
Bay v. Jensen, 147 Wash. App. 641 (Wash. Ct. App. 2008). “¶35 Under RCW 2.28.010(3), a trial court has the power to provide for the orderly conduct of proceedings before it.”
Bay v. Jensen, 196 P.3d 753 (Wash. Ct. App. 2008). “¶ 35 Under RCW 2.28.010(3), a trial court has the power to provide for the orderly conduct of proceedings before it.”
Wilson v. Henkle, 724 P.2d 1069 (Wash. Ct. App. 1986). “RCW 2.28.010(5) provides: Every court of justice has power—.”
Casper v. Esteb Enter., Inc., 82 P.3d 1223 (Wash. Ct. App. 2004). “And these attempts caused the trial court to respond in the manner that Esteb now claims is error. As we note above, though the trial court’s responses likely conveyed the court’s attitude about Esteb’s credibility to the jury, it was left little choice because of Esteb’s…”
State v. Sponburgh, 525 P.2d 238 (Wash. 1974). · cites it 2× “The protective order, which was entered concurrently with the order of dismissal, specifically retained the trial court's jurisdiction over the above-mentioned evidence by stating in two separate paragraphs that it was sealing all grand jury evidence "pending further order of…”
In Re The Pers. Restraint Petition Of Lia Yera Tricomo, 463 P.3d 760 (Wash. Ct. App. 2020). “030; RCW 2.28.010; RCW 2.28.150. Although Tricomo cites to these provisions, she provides no argument or analysis as to why these provisions should persuade us to hold that we have the authority to ignore the time-bar.”
Show all 56 citing cases →
— Wash. Rev. Code § 2.28.010(2) — 5 cases
Casper v. Esteb Enter., Inc., 82 P.3d 1223 (Wash. Ct. App. 2004). “And these attempts caused the trial court to respond in the manner that Esteb now claims is error. As we note above, though the trial court’s responses likely conveyed the court’s attitude about Esteb’s credibility to the jury, it was left little choice because of Esteb’s…”
State v. SH, 8 P.3d 1058 (Wash. Ct. App. 2000). “In a written order, the judge denied PDA's motion for reconsideration, citing RCW 2.28.010 and RCW 2.28.150. PDA appeals.”
State v. S.H., 102 Wash. App. 468 (Wash. Ct. App. 2000). “In a written order, the judge denied PDA’s motion for reconsideration, citing RCW 2.28.010 and RCW 2.28.150. PDA appeals.”
Casper v. Esteb Enter., Inc., 82 P.3d 1223 (Wash. Ct. App. 2004).
State v. S.H., 95 Wash. App. 741 (Wash. Ct. App. 1999).
— Wash. Rev. Code § 2.28.010(3) — 19 cases
Yurtis v. Phipps, 143 Wash. App. 680 (Wash. Ct. App. 2008). “RCW 2.28.010(3); In re Marriage of Lilly, 75 Wn.”
Bay v. Jensen, 147 Wash. App. 641 (Wash. Ct. App. 2008). “¶35 Under RCW 2.28.010(3), a trial court has the power to provide for the orderly conduct of proceedings before it.”
Bay v. Jensen, 196 P.3d 753 (Wash. Ct. App. 2008). “¶ 35 Under RCW 2.28.010(3), a trial court has the power to provide for the orderly conduct of proceedings before it.”
In the Matter of Marriage of Giordano, 787 P.2d 51 (Wash. Ct. App. 1990).
In the Matter of Marriage of Lilly, 880 P.2d 40 (Wash. Ct. App. 1994).
— Wash. Rev. Code § 2.28.010(4) — 3 cases
In Re The Marriage Of: Kathryn M. Cox, V. John Joseph Cox, 501 P.3d 155 (Wash. Ct. App. 2021).
State Of Washington, Appellant/cross-respondent V. Tylor Sean Donnelly, Respondent/cross-appellant (Wash. Ct. App. 2022).
In the Matter of the Marriage of Mona Kelley & Donald Kelley (Wash. Ct. App. 2026).
— Wash. Rev. Code § 2.28.010(5) — 5 cases
Wilson v. Henkle, 724 P.2d 1069 (Wash. Ct. App. 1986). “RCW 2.28.010(5) provides: Every court of justice has power—.”
Crossler v. Hille, 961 P.2d 327 (Wash. 1998).
In re Recall of Riddle (Wash. 2017).
In re Recall of Riddle (Wash. 2017).
In re Recall of Riddle (Wash. 2017).
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