Revised Code of Washington
Wash. Rev. Code § 26.09.197 (2026)
✓ current as of May 2026
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After considering the affidavit required by RCW 26.09.194(1) and other relevant evidence presented, the court shall make a temporary parenting plan that is in the best interest of the child. In making this determination, the court shall give particular consideration to:
(1) The relative strength, nature, and stability of the child's relationship with each parent; and
(2) Which parenting arrangements will cause the least disruption to the child's emotional stability while the action is pending.
The court shall also consider the factors used to determine residential provisions in the permanent parenting plan.
Notes:
Part headings not law—2007 c 496: See note following RCW 26.09.002.
Notes of Decisions
Cited in 7
cases (1 in the last 5 years), 1993–2025 · leading case: In re Long, 421 P.3d 989 (Wash. Ct. App. 2018).
In re Long, 421 P.3d 989 (Wash. Ct. App. 2018). “The order did not violate the doctrine of comity or RCW 26.09.197. We affirm. FACTS ¶ 3 Borrello is an Italian citizen, and Chandra Long is a United States citizen who grew up in Everett, Washington.”
In Re the Marriage of Kovacs, 854 P.2d 629 (Wash. 1993). “RCW 26.09.197 requires a trial court awarding temporary residential placement to "give particular consideration" to (1) which parent has taken greater responsibility during the last 12 months for performing parenting functions relating to the daily needs of the child and (2)…”
State v. Veliz, 298 P.3d 75 (Wash. 2013). “Three days later, on August 25, 2008, the court entered a temporary parenting plan in the dissolution proceeding pursuant to RCW 26.09.197. The State has never amended the information.”
Michelangelo Borrello v. Chandra Long (Wash. Ct. App. 2018). “The order did not violate the doctrine of comity or RCW 26.09.197. We affirm. FACTS Borrello is an Italian citizen, and Chandra Long is a United States citizen who grew up in Everett, Washington.”
Erin D. Farrell-milosavljevic v. Zmajko Milosavljevic (Wash. Ct. App. 2018). “RCW 26.09.197. Therefore, the CRA factors would apply after the best interest factors have been considered for a residential schedule under a temporary parenting plan.”
In Re Aaron Ross Freudenburg, & Mikela Forshe Freudenburg (Wash. Ct. App. 2025). “191 limitations on her parenting time and that the trial court did not appropriately consider the RCW 26.09.197 factors for determining residential time in a temporary parenting plan.”
State v. Veliz (Wash. 2013). “Three days later, on August 25, 2008, the court entered a temporary parenting plan in the dissolution proceeding pursuant to RCW 26.09.197. The State has never amended the information.”
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