Wash. Rev. Code » Title 26 · Chapter 26.09
Revised Code of Washington

Wash. Rev. Code § 26.09.220 (2026)

✓ current as of May 2026
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(1)(a) The court may order an investigation and report concerning parenting arrangements for the child, or may appoint a guardian ad litem pursuant to RCW 26.12.175, or both. The investigation and report may be made by the guardian ad litem, court-appointed special advocate, the staff of the juvenile court, or other professional social service organization experienced in counseling children and families.
(b) An investigator is a person appointed as an investigator under RCW 26.12.050(1)(b) or any other third-party professional ordered or appointed by the court to provide an opinion, assessment, or evaluation regarding the creation or modification of a parenting plan.
(2) In preparing the report concerning a child, the investigator or person appointed under subsection (1) of this section may consult any person who may have information about the child and the potential parenting or custodian arrangements. Upon order of the court, the investigator or person appointed under subsection (1) of this section may refer the child to professional personnel for diagnosis. The investigator or person appointed under subsection (1) of this section may consult with and obtain information from medical, psychiatric, or other expert persons who have served the child in the past without obtaining the consent of the parent or the child's custodian; but the child's consent must be obtained if the child has reached the age of twelve, unless the court finds that the child lacks mental capacity to consent. If the requirements of subsection (3) of this section are fulfilled, the report by the investigator or person appointed under subsection (1) of this section may be received in evidence at the hearing.
(3) The investigator or person appointed under subsection (1) of this section shall provide his or her report to counsel and to any party not represented by counsel at least ten days prior to the hearing unless a shorter time is ordered by the court for good cause shown. The investigator or person appointed under subsection (1) of this section shall make available to counsel and to any party not represented by counsel his or her file of underlying data and reports, complete texts of diagnostic reports made to the investigator or appointed person pursuant to the provisions of subsection (2) of this section, and the names and addresses of all persons whom he or she has consulted. Any party to the proceeding may call the investigator or person appointed under subsection (1) of this section and any person whom the investigator or appointed person has consulted for cross-examination. A party may not waive the right of cross-examination prior to the hearing.
[ 2011 c 292 s 4; 1993 c 289 s 1; 1989 c 375 s 12; 1987 c 460 s 16; 1973 1st ex.s. c 157 s 22.]
Notes of Decisions
Cited in 41 cases (10 in the last 5 years), 1975–2025 · leading case: King v. King, 174 P.3d 659 (Wash. 2007).
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King v. King, 174 P.3d 659 (Wash. 2007). · cites it 2× “RCW 26.09.220. The GAL is provided at public expense where both parents are indigent.”
In re the Marriage of King, 162 Wash. 2d 378 (Wash. 2007). · cites it 2× “RCW 26.09.220. The GAL is provided at public expense where both parents are indigent.”
In Re Parentage of CAMA, 109 P.3d 405 (Wash. 2005). “The nature and extent of visitation, subject to these restrictions, is in the discretion of the court.”
Appel v. Appel, 154 Wash. 2d 52 (Wash. 2005). “(8) The court may order an investigation and report concerning the proposed visitation or may appoint a guardian ad litem as provided in RCW 26.09.220. (9) Visitation granted pursuant to this section shall be incorporated into the parenting plan for the child.”
In Re Custody of SHB, 74 P.3d 674 (Wash. Ct. App. 2003). · cites it 2× “Under RCW 26.09.220, the court is authorized to utilize such reports.”
Luby v. Dasilva, 118 Wash. App. 71 (Wash. Ct. App. 2003). · cites it 2× “Under RCW 26.09.220, the court is authorized to utilize such reports.”
Fernando v. Nieswandt, 940 P.2d 1380 (Wash. Ct. App. 1997). “RCW 26.09.220, 26.12.175. The guardian is expressly permitted to interview doctors or experts who have seen the child in the past and report those impressions to the court.”
Fernando v. Nieswandt, 940 P.2d 1380 (Wash. Ct. App. 1997). “RCW 26.09.220, 26.12.175. The guardian is expressly permitted to interview doctors or experts who have seen the child in the past and report those impressions to the court.”
In Re the Marriage of Croley, 588 P.2d 738 (Wash. 1978). “Testimony regarding the statutory factors was offered by a staff member of the family court and a psychiatrist as authorized by RCW 26.09.220. Both the father and mother testified as did a woman friend of the father and a teacher of one of the children.”
In Re The Dependency Of: Z.A., 540 P.3d 173 (Wash. Ct. App. 2023). “2d 1380 (1997) (citing RCW 26.09.220; RCW 26.12.175)). “In effect, she acts as a neutral advisor to the court and, in this sense, is an expert in the status and dynamics of that family who can offer a common sense impression to the court.”
Mecum v. Pomiak, 81 P.3d 154 (Wash. Ct. App. 2003). “09 provision, RCW 26.09.220, applied in a chapter 26.10 case.”
In re the Parentage of C.A.M.A., 120 Wash. App. 199 (Wash. Ct. App. 2004). “(8) The court may order an investigation and report concerning the proposed visitation or may appoint a guardian ad litem as provided in RCW 26.09.220. (9) Visitation granted pursuant to this section shall be incorporated into the parenting plan for the child.”
Show all 41 citing cases →
— Wash. Rev. Code § 26.09.220(1) — 4 cases
King v. King, 174 P.3d 659 (Wash. 2007). “RCW 26.09.220. The GAL is provided at public expense where both parents are indigent.”
In re the Marriage of King, 162 Wash. 2d 378 (Wash. 2007). “RCW 26.09.220. The GAL is provided at public expense where both parents are indigent.”
In Re Parenting & Support of Sml, 173 P.3d 967 (Wash. Ct. App. 2007).
In re the Parenting & Support of S.M.L., 142 Wash. App. 110 (Wash. Ct. App. 2007).
— Wash. Rev. Code § 26.09.220(1)(a) — 5 cases
Marriage Of Roger Christopher, V. Connie Christopher (Wash. Ct. App. 2021).
Juliana S. Straight, V. Ethan H. Straight (Wash. Ct. App. 2025).
In re the Marriage of Paul A. Cardwell & Regan R. Cardwell (Wash. Ct. App. 2018).
Michaelangelo Borrello v. Chandra Long (Wash. Ct. App. 2020).
In Re The Marriage Of: Teresa G. Harkenrider v. Christopher A. Wodja (Wash. Ct. App. 2015).
— Wash. Rev. Code § 26.09.220(2) — 1 case
Parenting & Support Of Z.c., Cory Clarke V. Taylor Dike Kna Savage (Wash. Ct. App. 2023).
— Wash. Rev. Code § 26.09.220(3) — 5 cases
In re the Marriage of True, 16 P.3d 646 (Wash. Ct. App. 2000).
In Re The Marriage Of Robert Reichert v. Jennifer Reichert (Wash. Ct. App. 2018).
In Re The Marriage Of: Catherine Fan v. Shane Antos (Wash. Ct. App. 2019).
Grzegorz Gogolowicz, Appellant\\cross-respondent v. Magdalena Gogolowicz, Respondent\\cross-appellant (Wash. Ct. App. 2021).
Simon Bruce Sotheron v. Meagan Anastasia Palmer (Wash. Ct. App. 2014).
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