Revised Code of Washington
Wash. Rev. Code § 21.20.010 (2026)
Unlawful offers, sales, purchases
✓ current as of May 2026
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It is unlawful for any person, in connection with the offer, sale or purchase of any security, directly or indirectly:
(1) To employ any device, scheme, or artifice to defraud;
(2) To make any untrue statement of a material fact or to omit to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading; or
(3) To engage in any act, practice, or course of business which operates or would operate as a fraud or deceit upon any person.
[ 1959 c 282 s 1.]
Notes of Decisions
Cited in 118
cases (15 in the last 5 years), 1970–2026 · leading case: Fed. Home Loan Bank of Seattle v. Credit Suisse Sec. (USA) LLC, 449 P.3d 1019 (Wash. 2019).
Fed. Home Loan Bank of Seattle v. Credit Suisse Sec. (USA) LLC, 449 P.3d 1019 (Wash. 2019). “95436-4 It is unlawful for any person, in connection with the offer, sale or purchase of any security, directly or indirectly: (1) To employ any device, scheme, or artifice to defraud; (2)To make any untrue statement of a material fact or to omit to state a material fact…”
Haberman v. Washington Pub. Power Supply Sys., 750 P.2d 254 (Wash. 1988). “430(1) which provides that: Any person, who offers or sells a security in violation of any provisions of RCW 21.20.010 or 21.20.140 through 21.20.”
Golberg v. Sanglier, 639 P.2d 1347 (Wash. 1982). “In March 1978, Golberg and Pierce commenced this action, seeking damages under the partnership agreement based on fraud, breach of the partnership agreement and fiduciary duties, and violation of RCW 21.20.010 of the Washington securities laws.”
Hoffer v. State, 755 P.2d 781 (Wash. 1988). “In the first situation, "[a]ny person, who offers or sells a security in violation of any provisions of RCW 21.20.010 or 21.20.140 through 21.20.”
State v. Philips, 741 P.2d 24 (Wash. 2009). “Petitioners were convicted of several counts of securities fraud — RCW 21.20.010. They argue that the promissory notes that they marketed to investors were not securities; that their cases should have been severed; and that their individual convictions were not supported by…”
Kinney v. Cook, 154 P.3d 206 (Wash. 2007). “See RCW 21.20.010. 3 The statute has two essential elements: (1) a fraudulent or deceitful act committed (2) in “connection with the offer, sale or purchase of any security.”
Golberg v. Sanglier, 616 P.2d 1239 (Wash. Ct. App. 1980). “red into a partnership in 1974; that Sanglier and Carras thereafter successfully conspired to defeat the other partners' interests; that Sanglier and Carras obtained a dissolution of the partnership by means of fraud and misrepresentation; that Sanglier and Carras breached their…”
Brin v. Stutzman, 951 P.2d 291 (Wash. Ct. App. 1998). “430(1) for Stutzman’s alleged violation of RCW 21.20.010 and damages under an implied private cause of action for his alleged violation of RCW 21.”
Guarino v. Interactive Objects, Inc., 86 P.3d 1175 (Wash. Ct. App. 2004). “RCW 21.20.010 states in relevant part: It is unlawful for any person, in connection with the offer, sale, or purchase of any security, directly or indirectly: (1) To employ any device, scheme, or artifice to defraud; (2) To make any untrue statement of a material fact or to omit…”
Guarino v. Interactive Objects, Inc., 122 Wash. App. 95 (Wash. Ct. App. 2004). “RCW 21.20.010 states in relevant part: It is unlawful for any person, in connection with the offer, sale or purchase of any security, directly or indirectly: (1) To employ any device, scheme, or artifice to defraud; (2) To make any untrue statement of a material fact or to omit…”
Ludwig v. Mut. Real Est. Investors, 567 P.2d 658 (Wash. Ct. App. 1977). “Additionally, and even though the issue of his personal liability was not specifically pleaded, the trial judge found defendant Hellriegel personally responsible for MRI's failure to disclose certain material facts in violation of the *37 provisions of RCW 21.20.010. 1 More…”
Helenius v. Chelius, 120 P.3d 954 (Wash. Ct. App. 2005). “430(2) provides: Any person who buys a security in violation of the provisions of RCW 21.20.010 is liable to the person selling the security to him or her, who may sue either at law or in equity to recover the security, together *960 with any income received on the security,…”
— Wash. Rev. Code § 21.20.010(1) — 6 cases
Goel v. Jain, 259 F. Supp. 2d 1128 (W.D. Wash. 2003).
Fed. Home Loan Bank of Seattle v. Credit Suisse Sec. (USA) LLC, 449 P.3d 1019 (Wash. 2019). “95436-4 It is unlawful for any person, in connection with the offer, sale or purchase of any security, directly or indirectly: (1) To employ any device, scheme, or artifice to defraud; (2)To make any untrue statement of a material fact or to omit to state a material fact…”
Kinney v. Cook, 154 P.3d 206 (Wash. 2007).
State v. Eilts, 617 P.2d 993 (Wash. 1980).
Peter Graham, Et Ano., Resps v. Jeffery A. Mascio, Et Ano., Apps (Wash. Ct. App. 2018).
— Wash. Rev. Code § 21.20.010(2) — 42 cases
Golberg v. Sanglier, 639 P.2d 1347 (Wash. 1982). “In March 1978, Golberg and Pierce commenced this action, seeking damages under the partnership agreement based on fraud, breach of the partnership agreement and fiduciary duties, and violation of RCW 21.20.010 of the Washington securities laws.”
Haberman v. Washington Pub. Power Supply Sys., 750 P.2d 254 (Wash. 1988). “430(1) which provides that: Any person, who offers or sells a security in violation of any provisions of RCW 21.20.010 or 21.20.140 through 21.20.”
Fed. Home Loan Bank of Seattle v. Credit Suisse Sec. (USA) LLC, 449 P.3d 1019 (Wash. 2019). “95436-4 It is unlawful for any person, in connection with the offer, sale or purchase of any security, directly or indirectly: (1) To employ any device, scheme, or artifice to defraud; (2)To make any untrue statement of a material fact or to omit to state a material fact…”
Go2net, Inc. v. FreeYellow.com, Inc., 143 P.3d 590 (Wash. 2006).
State v. Reeder, 365 P.3d 1243 (Wash. 2015).
— Wash. Rev. Code § 21.20.010(3) — 4 cases
Golberg v. Sanglier, 639 P.2d 1347 (Wash. 1982). “In March 1978, Golberg and Pierce commenced this action, seeking damages under the partnership agreement based on fraud, breach of the partnership agreement and fiduciary duties, and violation of RCW 21.20.010 of the Washington securities laws.”
State v. Philips, 741 P.2d 24 (Wash. 2009). “Petitioners were convicted of several counts of securities fraud — RCW 21.20.010. They argue that the promissory notes that they marketed to investors were not securities; that their cases should have been severed; and that their individual convictions were not supported by…”
Haberman v. Washington Pub. Power Supply Sys., 750 P.2d 254 (Wash. 1988). “430(1) which provides that: Any person, who offers or sells a security in violation of any provisions of RCW 21.20.010 or 21.20.140 through 21.20.”
Golberg v. Sanglier, 616 P.2d 1239 (Wash. Ct. App. 1980). “red into a partnership in 1974; that Sanglier and Carras thereafter successfully conspired to defeat the other partners' interests; that Sanglier and Carras obtained a dissolution of the partnership by means of fraud and misrepresentation; that Sanglier and Carras breached their…”
— Wash. Rev. Code § 21.20.010(l) — 1 case
State v. Philips, 741 P.2d 24 (Wash. 2009). “Petitioners were convicted of several counts of securities fraud — RCW 21.20.010. They argue that the promissory notes that they marketed to investors were not securities; that their cases should have been severed; and that their individual convictions were not supported by…”
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