Wash. Rev. Code » Title 2 · Chapter 2.44
Revised Code of Washington

Wash. Rev. Code § 2.44.010 (2026)

Authority of attorney

✓ current as of May 2026
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An attorney and counselor has authority:
(1) To bind his or her client in any of the proceedings in an action or special proceeding by his or her agreement duly made, or entered upon the minutes of the court; but the court shall disregard all agreements and stipulations in relation to the conduct of, or any of the proceedings in, an action or special proceeding unless such agreement or stipulation be made in open court, or in presence of the clerk, and entered in the minutes by him or her, or signed by the party against whom the same is alleged, or his or her attorney;
(2) To receive money claimed by his or her client in an action or special proceeding, during the pendency thereof, or after judgment upon the payment thereof, and not otherwise, to discharge the same or acknowledge satisfaction of the judgment;
(3) This section shall not prevent a party from employing a new attorney or from issuing an execution upon a judgment, or from taking other proceedings prescribed by statute for its enforcement.
[ 2011 c 336 s 57; Code 1881 s 3280; 1863 p 404 s 6; RRS s 130.]
Notes of Decisions
Cited in 49 cases (9 in the last 5 years), 1971–2025 · leading case: Lavigne v. Green, 23 P.3d 515 (Wash. Ct. App. 2001).
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Lavigne v. Green, 23 P.3d 515 (Wash. Ct. App. 2001). · cites it 8× “Lavigne argues that CR 2A and RCW 2.44.010 preclude the enforcement of the disputed settlement agreement.”
Lavigne v. Green, 23 P.3d 515 (Wash. Ct. App. 2001). · cites it 8× “Lavigne argues that CR 2A and RCW 2.44.010 preclude the enforcement of the disputed settlement agreement.”
Morris v. Maks, 850 P.2d 1357 (Wash. Ct. App. 1993). · cites it 8× “In this case we are asked to decide whether the trial court erred in enforcing a settlement agreement under CR 2A and RCW 2.44.010. We hold that the trial court did not abuse its discretion in enforcing the settlement agreement and therefore affirm.”
In Re the Marriage of Ferree & Ferree, 856 P.2d 706 (Wash. Ct. App. 1993). · cites it 4× “B RCW 2.44.010 provides: An attorney. . . has authority: (1) To bind his client in any of the proceedings in an action or special proceeding by his agreement duly made, or entered *46 upon the minutes of the court; but the court shall disregard all agreements and stipulations in…”
Bryant v. Palmer Coking Coal Co., 834 P.2d 662 (Wash. Ct. App. 1993). · cites it 8× “In this case we decide that a settlement agreement allegedly entered into by the parties is unenforceable because it does not satisfy the requirements of CR 2A or RCW 2.44.010. I The Bryants brought a quiet title action against Palmer Coking Coal Company (Palmer), claiming…”
Stottlemyre v. Reed, 665 P.2d 1383 (Wash. Ct. App. 1983). · cites it 4× “RCW 2.44.010 was satisfied when this questioning took place in open court and became part of the record.”
In re the Marriage of Langham, 153 Wash. 2d 553 (Wash. 2005). · cites it 2× “¶18 RCW 2.44.010 5 and CR 2A allow attorneys to enter binding agreements on behalf of their clients.”
In Re Marriage of Langham, 106 P.3d 212 (Wash. 2005). · cites it 2× “RCW 2.44.010 [5] and CR 2A allow attorneys to enter binding agreements on behalf of their clients.”
State v. Briggs, 971 P.2d 581 (Wash. Ct. App. 1999). · cites it 4× “He contends the judgment is void because it did not comply with CR 2A or RCW 2.44.010. CR 2A provides authority for entry of a stipulated settlement and judgment.”
Howard v. DiMaggio, 855 P.2d 335 (Wash. Ct. App. 1993). · cites it 4× “RCW 2.44.010 provides, in part: An attorney and counselor has authority: (1) To bind his client in any of the proceedings in an action or special proceeding by his agreement duly made, or entered *738 upon the minutes of the court; but the court shall disregard all agreements…”
In re Dependency of E.M., 484 P.3d 461 (Wash. 2021). “See RCW 2.44.010 (statute confers power to bind a “client”).”
Nguyen v. Sacred Heart Med. Ctr., 987 P.2d 634 (Wash. Ct. App. 1999). · cites it 3× “Concessions The issue is whether the trial court erred by accepting the Nguyens’ concession through their trial counsel that their claims were limited to “ ‘A’ a worsening of a birth condition, or ‘B’, loss of a chance at a better outcome.”
Show all 49 citing cases →
— Wash. Rev. Code § 2.44.010(1) — 12 cases
Lavigne v. Green, 23 P.3d 515 (Wash. Ct. App. 2001). “Lavigne argues that CR 2A and RCW 2.44.010 preclude the enforcement of the disputed settlement agreement.”
Lavigne v. Green, 23 P.3d 515 (Wash. Ct. App. 2001). “Lavigne argues that CR 2A and RCW 2.44.010 preclude the enforcement of the disputed settlement agreement.”
In Re the Marriage of Ferree & Ferree, 856 P.2d 706 (Wash. Ct. App. 1993). “B RCW 2.44.010 provides: An attorney. . . has authority: (1) To bind his client in any of the proceedings in an action or special proceeding by his agreement duly made, or entered *46 upon the minutes of the court; but the court shall disregard all agreements and stipulations in…”
Stottlemyre v. Reed, 665 P.2d 1383 (Wash. Ct. App. 1983). “RCW 2.44.010 was satisfied when this questioning took place in open court and became part of the record.”
Rathvon v. Columbia Pac. Airlines, 633 P.2d 122 (Wash. Ct. App. 1981).
— Wash. Rev. Code § 2.44.010(2) — 1 case
Talon Cutler-Flinn, V Washington State Dept. Of Corr. (Wash. Ct. App. 2024).
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.