Revised Code of Washington

Wash. Rev. Code § 26.09.184 (2026)

Permanent parenting plan

✓ current as of May 2026

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(1) OBJECTIVES. The objectives of the permanent parenting plan are to:

(a) Provide for the child's physical care;

(b) Maintain the child's emotional stability;

(c) Provide for the child's changing needs as the child grows and matures, in a way that minimizes the need for future modifications to the permanent parenting plan;

(d) Set forth the authority and responsibilities of each parent with respect to the child, consistent with the criteria in RCW 26.09.187 and 26.09.191;

(e) Minimize the child's exposure to harmful parental conflict;

(f) Encourage the parents, where appropriate under RCW 26.09.187 and 26.09.191, to meet their responsibilities to their minor children through agreements in the permanent parenting plan, rather than by relying on judicial intervention; and

(g) To otherwise protect the best interests of the child consistent with RCW 26.09.002.

(2) CONTENTS OF THE PERMANENT PARENTING PLAN. The permanent parenting plan shall contain provisions for resolution of future disputes between the parents, allocation of decision-making authority, and residential provisions for the child.

(3) CONSIDERATION IN ESTABLISHING THE PERMANENT PARENTING PLAN. In establishing a permanent parenting plan, the court may consider the cultural heritage and religious beliefs of a child.

(4) DISPUTE RESOLUTION. A process for resolving disputes, other than court action, shall be provided unless precluded or limited by RCW 26.09.187 or 26.09.191. A dispute resolution process may include counseling, mediation, or arbitration by a specified individual or agency, or court action. In the dispute resolution process:

(a) Preference shall be given to carrying out the parenting plan;

(b) The parents shall use the designated process to resolve disputes relating to implementation of the plan, except those related to financial support, unless an emergency exists;

(c) A written record shall be prepared of any agreement reached in counseling or mediation and of each arbitration award and shall be provided to each party;

(d) If the court finds that a parent has used or frustrated the dispute resolution process without good reason, the court shall award attorneys' fees and financial sanctions to the prevailing parent;

(e) The parties have the right of review from the dispute resolution process to the superior court; and

(f) The provisions of (a) through (e) of this subsection shall be set forth in the decree.

(5) ALLOCATION OF DECISION-MAKING AUTHORITY.

(a) The plan shall allocate decision-making authority to one or both parties regarding the children's education, health care, and religious upbringing. The parties may incorporate an agreement related to the care and growth of the child in these specified areas, or in other areas, into their plan, consistent with the criteria in RCW 26.09.187 and 26.09.191. Regardless of the allocation of decision-making in the parenting plan, either parent may make emergency decisions affecting the health or safety of the child.

(b) Each parent may make decisions regarding the day-to-day care and control of the child while the child is residing with that parent.

(c) When mutual decision making is designated but cannot be achieved, the parties shall make a good faith effort to resolve the issue through the dispute resolution process.

(6) RESIDENTIAL PROVISIONS FOR THE CHILD. The plan shall include a residential schedule which designates in which parent's home each minor child shall reside on given days of the year, including provision for holidays, birthdays of family members, vacations, and other special occasions, consistent with the criteria in RCW 26.09.187 and 26.09.191.

(7) PARENTS' OBLIGATION UNAFFECTED. If a parent fails to comply with a provision of a parenting plan or a child support order, the other parent's obligations under the parenting plan or the child support order are not affected. Failure to comply with a provision in a parenting plan or a child support order may result in a finding of contempt of court, under RCW 26.09.160.

(8) PROVISIONS TO BE SET FORTH IN PERMANENT PARENTING PLAN. The permanent parenting plan shall set forth the provisions of subsections (4)(a) through (c), (5)(b) and (c), and (7) of this section.

[ 2007 c 496 s 601; 1991 c 367 s 7; 1989 c 375 s 9; 1987 c 460 s 8.]

Notes:

Part headings not law—2007 c 496: See note following RCW 26.09.002.

Severability—Effective date—Captions not law—1991 c 367: See notes following RCW 26.09.015.

Custody, designation of for purposes of other statutes: RCW 26.09.285.

Failure to comply with decree or temporary injunction—Obligations not suspended: RCW 26.09.160.

Notes of Decisions

Cited in 106 cases (20 in the last 5 years), 1992–2026 · leading case: In Re the Parentage of Smith-Bartlett, 976 P.2d 173 (Wash. Ct. App. 1999).

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In Re the Parentage of Smith-Bartlett, 976 P.2d 173 (Wash. Ct. App. 1999). · cites it 17× “Bartlett points out, this is inconsistent with RCW 26.09.184’s stated intent to divert squabbles over visitation from the courts.”

In re the Marriage of Coy, 160 Wash. App. 797 (Wash. Ct. App. 2011). · cites it 5× “140, and (2) Mark’s use or frustration of the dispute resolution process without good reason, under RCW 26.09.184(4)(d). 3 Mark timely appeals.”

In Re Marriage of Possinger, 19 P.3d 1109 (Wash. Ct. App. 2001). · cites it 3× “RCW 26.09.184(1) lists the objectives of permanent parenting plans, one of which is to "[p]rovide for the child's changing needs as the child grows and matures, in a way that minimizes the need for future modifications to the permanent parenting plan[.”

In Re Marriage of Wilson, 68 P.3d 1121 (Wash. Ct. App. 2003). · cites it 4× “" Agreed parenting plans further the objectives found in RCW 26.09.184(1). These objectives stress a child's physical care, emotional stability, and changing needs.”

In re the Marriage of Possinger, 105 Wash. App. 326 (Wash. Ct. App. 2001). · cites it 3× “RCW 26.09.184(1) lists the objectives of permanent parenting plans, one of which is to “[p]rovide for the child’s changing needs as the child grows and matures, in a way that minimizes the need for future modifications to the permanent parenting plan[.”

In Re the Marriage of Jensen-Branch, 899 P.2d 803 (Wash. Ct. App. 1995). · cites it 5× “) RCW 26.09.184(4)(a). The trial court "shall order” sole decision-making authority to one parent if one parent is opposed to joint decision making and that opposition is reasonable under RCW 26.”

In Re the Marriage of Kovacs, 854 P.2d 629 (Wash. 1993). · cites it 2× “RCW 26.09.184(1). (3) RESIDENTIAL PROVISIONS.”

In re the Marriage of Kim, 317 P.3d 555 (Wash. Ct. App. 2014). · cites it 2× “¶47 RCW 26.09.184(3) provides, “In establishing a permanent parenting plan, the court may consider the cultural heritage and religious beliefs of a child.”

In re the Marriage of Wilson, 117 Wash. App. 40 (Wash. Ct. App. 2003). · cites it 3× “RCW 26.09.184 (l)(a)-(c). The aim is to set parental responsibilities, minimize harmful parental conflicts, and encourage agreements in parenting plans without judicial intervention.”

In re the Marriage of Katare, 283 P.3d 546 (Wash. 2012). “187(3) (enumer *36 ating factors to be considered when constructing a parenting plan), RCW 26.09.184 (setting forth the objectives of the permanent parenting plan and the required provisions), RCW 26.”

In re the Marriage of Pape, 989 P.2d 1120 (Wash. 1999). · cites it 3× “002, RCW 26.09.184(1)(f). The Court of Appeals was correct when it stated that “parents should generally be able to enforce such agreed restrictions, so long as such enforcement is in the best interests of the children.”

In Re Parentage of LB, 122 P.3d 161 (Wash. 2005). “See generally RCW 26.09.184. [22] While not contested here, it is evident that child support obligations, while now addressed by statutes, continue to be additionally addressed through the common law and its adaptations.”

Show all 106 citing cases →

— Wash. Rev. Code § 26.09.184(1) — 14 cases

In Re the Marriage of Kovacs, 854 P.2d 629 (Wash. 1993). “RCW 26.09.184(1). (3) RESIDENTIAL PROVISIONS.”

In Re Marriage of Possinger, 19 P.3d 1109 (Wash. Ct. App. 2001). “RCW 26.09.184(1) lists the objectives of permanent parenting plans, one of which is to "[p]rovide for the child's changing needs as the child grows and matures, in a way that minimizes the need for future modifications to the permanent parenting plan[.”

In re the Marriage of Possinger, 105 Wash. App. 326 (Wash. Ct. App. 2001). “RCW 26.09.184(1) lists the objectives of permanent parenting plans, one of which is to “[p]rovide for the child’s changing needs as the child grows and matures, in a way that minimizes the need for future modifications to the permanent parenting plan[.”

State v. Fairfax, 179 Wash. 2d 411 (Wash. 2013).

Matter of Marriage of Kovacs, 840 P.2d 214 (Wash. Ct. App. 1992).

— Wash. Rev. Code § 26.09.184(1)(a) — 4 cases

In Re Marriage of Wilson, 68 P.3d 1121 (Wash. Ct. App. 2003). “" Agreed parenting plans further the objectives found in RCW 26.09.184(1). These objectives stress a child's physical care, emotional stability, and changing needs.”

Teresa Sciarretta, V. Ngonidzashe Chikoore (Wash. Ct. App. 2021).

In Re: Lori Price, & Jesse Price (Wash. Ct. App. 2023).

Allan R. Teravainen, V. Natalie R. Teravainen, Nka Sullivan (Wash. Ct. App. 2026).

— Wash. Rev. Code § 26.09.184(1)(c) — 5 cases

Matter of Marriage of Kovacs, 840 P.2d 214 (Wash. Ct. App. 1992).

Link v. Link, 268 P.3d 963 (Wash. Ct. App. 2011).

In re the Parentage of: A.R. (Wash. Ct. App. 2017).

Alice H. Argosino v. Mark W. Bryan (Wash. Ct. App. 2020).

— Wash. Rev. Code § 26.09.184(1)(d) — 1 case

— Wash. Rev. Code § 26.09.184(1)(e) — 2 cases

In Re The Marriage Of: Lance G. Rounds v. Brinetter R. Rounds, 423 P.3d 895 (Wash. Ct. App. 2018).

Andrea J. Clare v. Kevin P. Clare (Wash. Ct. App. 2021).

— Wash. Rev. Code § 26.09.184(1)(f) — 3 cases

In re the Marriage of Pape, 989 P.2d 1120 (Wash. 1999). “002, RCW 26.09.184(1)(f). The Court of Appeals was correct when it stated that “parents should generally be able to enforce such agreed restrictions, so long as such enforcement is in the best interests of the children.”

In Re Marriage of Pape, 989 P.2d 1120 (Wash. 2000).

Justine Becker, V. Matthew Cole (Wash. Ct. App. 2025).

— Wash. Rev. Code § 26.09.184(1)(g) — 7 cases

In re the Parentage of: A.R. (Wash. Ct. App. 2017).

Sarah Marie Vanderlinden v. Nicolas Gonzalez Vanderlinden (Wash. Ct. App. 2019).

In the Matter of the Custody of: SA-M (Wash. Ct. App. 2021).

— Wash. Rev. Code § 26.09.184(2) — 12 cases

King v. King, 174 P.3d 659 (Wash. 2007).

In re the Marriage of King, 162 Wash. 2d 378 (Wash. 2007).

In re the Marriage of Holmes, 128 Wash. App. 727 (Wash. Ct. App. 2005).

In Re Marriage Holmes, 117 P.3d 370 (Wash. Ct. App. 2005).

State v. Pesta, 942 P.2d 1013 (Wash. Ct. App. 1997).

— Wash. Rev. Code § 26.09.184(3) — 12 cases

In Re the Parentage of Smith-Bartlett, 976 P.2d 173 (Wash. Ct. App. 1999). “Bartlett points out, this is inconsistent with RCW 26.09.184’s stated intent to divert squabbles over visitation from the courts.”

In re the Marriage of Kim, 317 P.3d 555 (Wash. Ct. App. 2014). “¶47 RCW 26.09.184(3) provides, “In establishing a permanent parenting plan, the court may consider the cultural heritage and religious beliefs of a child.”

Godfrey v. Hartford Cas. Ins., 142 Wash. 2d 885 (Wash. 2001).

Godfrey v. Hartford Cas. Ins. Co., 16 P.3d 617 (Wash. 2001).

Kirshenbaum v. Kirshenbaum, 929 P.2d 1204 (Wash. Ct. App. 1997).

— Wash. Rev. Code § 26.09.184(3)(b) — 3 cases

In Re Marriage of Pape, 989 P.2d 1120 (Wash. 2000).

— Wash. Rev. Code § 26.09.184(3)(d) — 1 case

— Wash. Rev. Code § 26.09.184(3)(e) — 5 cases

Kirshenbaum v. Kirshenbaum, 929 P.2d 1204 (Wash. Ct. App. 1997).

In Re The Parentage Of M.r.k.: Michelle Hansen v. Peter Gerald Kohl (Wash. Ct. App. 2014).

Alice H. Argosino v. Mark W. Bryan (Wash. Ct. App. 2020).

In Re: Tony Balevski, V. Aleksandra Danilov (Wash. Ct. App. 2024).

— Wash. Rev. Code § 26.09.184(4) — 12 cases

Mehmet Serkan Ketenci, V. Aino Kaarina Ketenci (Wash. Ct. App. 2024).

In Re The Parenting & Support Of: A.p. David Parsons, Res. v. Tanya Goodman, App. (Wash. Ct. App. 2019).

Alice H. Argosino v. Mark W. Bryan (Wash. Ct. App. 2020).

In Re: Alexi Mikele Turner, & Michael Matthew Turner (Wash. Ct. App. 2023).

In Re The Parentage Of M.r.k.: Michelle Hansen v. Peter Gerald Kohl (Wash. Ct. App. 2014).

— Wash. Rev. Code § 26.09.184(4)(a) — 3 cases

In Re the Marriage of Jensen-Branch, 899 P.2d 803 (Wash. Ct. App. 1995). “) RCW 26.09.184(4)(a). The trial court "shall order” sole decision-making authority to one parent if one parent is opposed to joint decision making and that opposition is reasonable under RCW 26.”

In Re: Alexi Mikele Turner, & Michael Matthew Turner (Wash. Ct. App. 2023).

In re the Marriage of: Norman D. Leslie & Janelle L. Leslie (Wash. Ct. App. 2013).

— Wash. Rev. Code § 26.09.184(4)(b) — 2 cases

In Re The Parenting & Support Of: A.p. David Parsons, Res. v. Tanya Goodman, App. (Wash. Ct. App. 2019).

Michelle Conley, V. Christopher Rugh (Wash. Ct. App. 2021).

— Wash. Rev. Code § 26.09.184(4)(c) — 2 cases

In Re Marriage of Pape, 989 P.2d 1120 (Wash. 2000).

— Wash. Rev. Code § 26.09.184(4)(d) — 4 cases

In re the Marriage of Coy, 160 Wash. App. 797 (Wash. Ct. App. 2011). “140, and (2) Mark’s use or frustration of the dispute resolution process without good reason, under RCW 26.09.184(4)(d). 3 Mark timely appeals.”

In Re Marriage of Coy, 248 P.3d 1101 (Wash. Ct. App. 2011).

In Re The Parenting & Support Of: A.p. David Parsons, Res. v. Tanya Goodman, App. (Wash. Ct. App. 2019).

Teresa Sciarretta, V. Ngonidzashe Chikoore (Wash. Ct. App. 2021).

— Wash. Rev. Code § 26.09.184(4)(e) — 8 cases

In Re Marriage of Coy, 248 P.3d 1101 (Wash. Ct. App. 2011).

In Re The Parentage Of M.r.k.: Michelle Hansen v. Peter Gerald Kohl (Wash. Ct. App. 2014).

Jessica Lee Bodge v. Brian Eugene Bodge (Wash. Ct. App. 2018).

— Wash. Rev. Code § 26.09.184(5) — 8 cases

In Re the Marriage of Kovacs, 854 P.2d 629 (Wash. 1993). “RCW 26.09.184(1). (3) RESIDENTIAL PROVISIONS.”

In re the Parentage of M.F., 141 Wash. App. 558 (Wash. Ct. App. 2007).

In Re Marriage of Coy, 248 P.3d 1101 (Wash. Ct. App. 2011).

In Re Parentage of MF, 170 P.3d 601 (Wash. Ct. App. 2007).

— Wash. Rev. Code § 26.09.184(5)(a) — 12 cases

Shawna Hubbard, Resp. v. Marcus Ross, App. (Wash. Ct. App. 2016).

In Re Marriage Of: Eric R. Shibley, App. v. Tina M. Shibley, Resp. (Wash. Ct. App. 2016).

Sarah Marie Vanderlinden v. Nicolas Gonzalez Vanderlinden (Wash. Ct. App. 2019).

Christy M. Mckinley v. Benjamin S. Porter (Wash. Ct. App. 2019).

Janene Gordon, App./Cross-Resp. v. Scott K. Serven, Resp./Cross-App. (Wash. Ct. App. 2025).

— Wash. Rev. Code § 26.09.184(5)(b) — 1 case

Jennifer Young Luna v. Neal Harold Luna (Wash. Ct. App. 2016).

— Wash. Rev. Code § 26.09.184(6) — 6 cases

In Re the Marriage of James, 903 P.2d 470 (Wash. Ct. App. 1995).

In Re the Marriage of Farr, 940 P.2d 679 (Wash. Ct. App. 1997).

In Re Marriage: Caroline Caylor, Aka Caroline Vaughan, App. v. Nathaniel Caylor, Resp. (Wash. Ct. App. 2016).

Justine Becker, V. Matthew Cole (Wash. Ct. App. 2025).

Michael Erickson v. Meela Pribic (Wash. Ct. App. 2020).

— Wash. Rev. Code § 26.09.184(7) — 4 cases

In re the Marriage of: Jeffrey K. Newgard & Pennelopy Ann Newgard (Wash. Ct. App. 2017).

In Re The Parenting & Support Of: A.p. David Parsons, Res. v. Tanya Goodman, App. (Wash. Ct. App. 2019).

Jennifer Lesinski, V. Joseph Mienko (Wash. Ct. App. 2022).

Jennifer M. McCluskey v. David A. Saunders (Wash. Ct. App. 2023).

— Wash. Rev. Code § 26.09.184(e) — 1 case

— Wash. Rev. Code § 26.09.184(g) — 1 case

In Re: Marriage Of Michael P. Bateman, Resp v. Mina K. Bateman, App (Wash. Ct. App. 2018).

— Wash. Rev. Code § 26.09.184(l)(b) — 1 case

— Wash. Rev. Code § 26.09.184(l)(c) — 4 cases

Kirshenbaum v. Kirshenbaum, 929 P.2d 1204 (Wash. Ct. App. 1997).

In Re the Marriage of Sheley, 895 P.2d 850 (Wash. Ct. App. 1995).

Link v. Link, 268 P.3d 963 (Wash. Ct. App. 2011).

— Wash. Rev. Code § 26.09.184(l)(f) — 2 cases

In re the Marriage of Pape, 968 P.2d 417 (Wash. Ct. App. 1998).

— Wash. Rev. Code § 26.09.184(l)(g) — 4 cases

In re the Marriage of Wilson, 117 Wash. App. 40 (Wash. Ct. App. 2003). “RCW 26.09.184 (l)(a)-(c). The aim is to set parental responsibilities, minimize harmful parental conflicts, and encourage agreements in parenting plans without judicial intervention.”

In Re the Marriage of Sheley, 895 P.2d 850 (Wash. Ct. App. 1995).

In Re the Marriage of Schneider, 918 P.2d 543 (Wash. Ct. App. 1996).

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