Revised Code of Washington
Wash. Rev. Code § 35.72.010 (2026)
Contracts authorized for street projects
✓ current as of May 2026
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The legislative authority of any city, town, or county may contract with owners of real estate for the construction or improvement of street projects which the owners elect to install as a result of ordinances that require the projects as a prerequisite to further property development.
[ 1983 c 126 s 1.]
Notes of Decisions
Cited in 4
cases (1 in the last 5 years), 1993–2023 · leading case: Cave Props. v. City Of Bainbridge Island, 199 Wash. App. 651 (Wash. Ct. App. 2017).
Cave Props. v. City Of Bainbridge Island, 199 Wash. App. 651 (Wash. Ct. App. 2017). “Sims, slip op. at 2. The city council voted to approve the latecomer reimbursement agreement.”
Woodcreek Land Ltd. Partnerships I, II, III & IV v. City of Puyallup, 847 P.2d 501 (Wash. Ct. App. 1993). “RCW 35.72.010. The contract may provide for the partial reimbursement to the owner or the owner's assigns for a period not to exceed fifteen years of a portion of the costs of the project by other property owners who: (1) Are determined to be within the assessment reimbursement…”
Vern Sims Fam. Ltd. P'ship v. City Of Burlington (Wash. Ct. App. 2016). “See RCW 35.72.010. The contracts enable developing property owners to be reimbursed for any excess benefit created by street improvements they make during the course of developing their property.”
Viking Jv, Llc, V. City Of Puyallup (Wash. Ct. App. 2023). “Following a challenge from one of the property owners, the court analyzed language from RCW 35.72.010 stating that a municipality “ ‘may contract with owners of real estate for the construction or improvement of street projects which the owners elect to install as a result of…”
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