Revised Code of Washington

Wash. Rev. Code § 26.33.070 (2026)

✓ current as of May 2026

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(1) The court shall appoint a guardian ad litem for any parent or *alleged father under eighteen years of age in any proceeding under this chapter. The court may appoint a guardian ad litem for a child adoptee or any incompetent party in any proceeding under this chapter. The guardian ad litem for a parent or *alleged father, in addition to determining what is in the best interest of the party, shall make an investigation and report to the court concerning whether any written consent to adoption or petition for relinquishment signed by the parent or *alleged father was signed voluntarily and with an understanding of the consequences of the action. If the child to be relinquished is a dependent child under chapter 13.34 RCW and the minor parent is represented by an attorney or guardian ad litem in the dependency proceeding, the court may rely on the minor parent's dependency court attorney or guardian ad litem to make a report to the court as provided in this subsection.

(2) The court in the county in which a petition is filed shall direct who shall pay the fees of a guardian ad litem or attorney appointed under this chapter and shall approve the payment of the fees. If the court orders the parties to pay the fees of the guardian ad litem, the fees must be established pursuant to the procedures in RCW 26.12.183.

[ 2011 c 292 s 3; 1984 c 155 s 7.]

Notes:

*Reviser's note: RCW 26.33.020 was amended by 2019 c 46 s 5034, changing the definition of "alleged father" to "alleged genetic parent."

Notes of Decisions

Cited in 9 cases, 2003–2020 · leading case: In Re Jn, 95 P.3d 414 (Wash. Ct. App. 2004).

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In Re Jn, 95 P.3d 414 (Wash. Ct. App. 2004). · cites it 4× “RCW 26.33.070. Under this statute, the GAL "shall make an investigation and report to the court concerning whether any written consent to adoption or petition for relinquishment signed by the parent or alleged father was signed voluntarily and with an understanding of the…”

In re the Welfare of J.N., 123 Wash. App. 564 (Wash. Ct. App. 2004). · cites it 4× “RCW 26.33.070. Under this statute, the GAL “shall make an investigation and report to the court concerning whether any written consent to adoption or petition for relinquishment signed by the parent or alleged father was signed voluntarily and with an understanding of the…”

In re the Welfare of H.Q., 330 P.3d 195 (Wash. Ct. App. 2014). · cites it 4× “In fact, RCW 26.33.070 expressly permits incompetent persons to seek appointment of a guardian or a GAL in an adoption proceeding.”

In Re Marriage of Furrow, 63 P.3d 821 (Wash. Ct. App. 2003). “Although the adoption statute does not require the appointment of a guardian ad litem for children who are the subject of a relinquishment and termination proceeding (an exception applies to Indian children), in that RCW 26.33.070 states that a court "may" appoint a guardian ad…”

In re the Marriage of Furrow, 115 Wash. App. 661 (Wash. Ct. App. 2003). “Although the adoption statute does not require the appointment of a guardian ad litem for children who are the subject of a relinquishment and termination proceeding (an exception applies to Indian children), in that RCW 26.33.070 states that a court “may’ appoint a guardian ad…”

Adoption of D.N.T. v. R.D.H., 843 So. 2d 690 (Miss. 2003). “Laws § 15-7-10 (2002); Wash. Rev.Code § 26.33.070 (2002). While it is true that these states have chosen to protect minor parents by statute, "the broad inherent equity powers of the chancery court” have been held to allow (for example) this Court to abolish the title system of…”

In Re Dependency Of: Z.f.s., Marie Smith v. Dshs (Wash. Ct. App. 2017). · cites it 2× “" The motion sought relief from the termination order under the following authorities: CR 60(b)(1)(irregularity in obtaining an order or judgment); CR 60(b)(2)(erroneous proceedings against a person of unsound mind not appearing on the record); CR 60(b)(11)(other reasons…”

Dep. Of Loe, Lbe, Lje Patricia Ann Walsh v. Dcyf (Wash. Ct. App. 2020). “11 Actual prejudice requires a “plausible showing by the [appellant] that the asserted error had practical and identifiable consequences in the trial of the case.”

— Wash. Rev. Code § 26.33.070(1) — 6 cases

In re the Welfare of H.Q., 330 P.3d 195 (Wash. Ct. App. 2014). “In fact, RCW 26.33.070 expressly permits incompetent persons to seek appointment of a guardian or a GAL in an adoption proceeding.”

In Re Jn, 95 P.3d 414 (Wash. Ct. App. 2004). “RCW 26.33.070. Under this statute, the GAL "shall make an investigation and report to the court concerning whether any written consent to adoption or petition for relinquishment signed by the parent or alleged father was signed voluntarily and with an understanding of the…”

In re the Welfare of J.N., 123 Wash. App. 564 (Wash. Ct. App. 2004). “RCW 26.33.070. Under this statute, the GAL “shall make an investigation and report to the court concerning whether any written consent to adoption or petition for relinquishment signed by the parent or alleged father was signed voluntarily and with an understanding of the…”

In Re Dependency Of: Z.f.s., Marie Smith v. Dshs (Wash. Ct. App. 2017). “" The motion sought relief from the termination order under the following authorities: CR 60(b)(1)(irregularity in obtaining an order or judgment); CR 60(b)(2)(erroneous proceedings against a person of unsound mind not appearing on the record); CR 60(b)(11)(other reasons…”

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