Wash. Rev. Code » Title 26 · Chapter 26.18
Revised Code of Washington

Wash. Rev. Code § 26.18.160 (2026)

Costs

✓ current as of May 2026
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In any action to enforce a support or maintenance order under this chapter, the prevailing party is entitled to a recovery of costs, including an award for reasonable attorney fees. An obligor may not be considered a prevailing party under this section unless the obligee has acted in bad faith in connection with the proceeding in question.
[ 1993 c 426 s 13; 1984 c 260 s 25.]
Notes of Decisions
Cited in 73 cases (14 in the last 5 years), 1986–2026 · leading case: Matter of Marriage of Nelson, 814 P.2d 1208 (Wash. Ct. App. 1991).
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Matter of Marriage of Nelson, 814 P.2d 1208 (Wash. Ct. App. 1991). · cites it 15× “Grossman was a prevailing party as that term is used in RCW 26.18.160, and finding the record incomplete regarding her claim for attorney fees in her modification action, we reverse and remand to the trial court.”
Johnson v. Cash Store, 116 Wash. App. 833 (Wash. Ct. App. 2003). · cites it 3× “Johnson requests attorney fees on appeal pursuant to RCW 26.18.160. Because this statute authorizes reasonable attorney fees and costs only in “any action to enforce a support or maintenance order under this chapter,” RCW 26.”
Johnson v. Cash Store, 68 P.3d 1099 (Wash. Ct. App. 2003). · cites it 3× “Johnson requests attorney fees on appeal pursuant to RCW 26.18.160. Because this statute authorizes reasonable attorney fees and costs only in "any action to enforce a support or maintenance order under this chapter," RCW 26.”
Bell v. Heflin, 383 P.3d 1031 (Wash. 2016). · cites it 3× “I, § 1, but the Court of Appeals rejected this claim because Bell provided no meaningful legal argument.”
In Re the Marriage of Hunter, 758 P.2d 1019 (Wash. Ct. App. 1988). · cites it 4× “The "applicable law" in this case is RCW 26.18.160, 4 which provides in part: In any action to enforce a support order under this chapter, the prevailing party is entitled to a recovery of costs, including an award for reasonable attorney fees.”
Rhinevault v. Rhinevault, 959 P.2d 687 (Wash. Ct. App. 1998). · cites it 2× “Rhinevault seeks costs and attorney fees on appeal under RCW 26.18.160: In any action to enforce a support or maintenance order under this chapter, the prevailing party is entitled to a recovery of costs, including an award for reasonable attorney fees.”
In re the Marriage of Lee, 310 P.3d 845 (Wash. Ct. App. 2013). · cites it 2× “040, and RCW 26.18.160 ” 4 RCW 26.18.160 mandates an award of reasonable attorney fees to the prevailing party in an action to enforce child support or spousal maintenance.”
In Re the Marriage of Mattson, 976 P.2d 157 (Wash. Ct. App. 1999). “Hall demonstrated her financial need and gave the trial courts full accounting for fees owed to her counsel.”
Bell v. Bell, 4 P.3d 849 (Wash. Ct. App. 2000). · cites it 2× “140 and RCW 26.18.160. RCW 26.09.140 allows this court to award attorney fees on appeal in any action under chapter 26.”
In re the Marriage of Abercrombie, 105 Wash. App. 239 (Wash. Ct. App. 2001). · cites it 2× “Finally, Abercrombie complains that the attorney fee award was not authorized by RCW 26.18.160 3 because Congleton did not file an action to enforce a support order.”
In re the Marriage of Bell, 101 Wash. App. 366 (Wash. Ct. App. 2000). · cites it 2× “140 and RCW 26.18.160. RCW 26.09.140 allows this court to award attorney fees on appeal in any action under chapter 26.”
Rains v. State, Dept. of Shs, Dcs, 989 P.2d 558 (Wash. Ct. App. 1999). · cites it 2× “Rains contends she is entitled to her attorney fees at both the trial level and on appeal pursuant to RCW 26.18.160. She further contends costs, excluding attorney fees, may be awarded under RCW 7.”
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