Revised Code of Washington

Wash. Rev. Code § 36.28.011 (2026)

Duty to make complaint

✓ current as of May 2026
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*** CHANGE IN 2026 *** (SEE 5974-S2.SL) ***
In addition to the duties contained in RCW 36.28.010, it shall be the duty of all sheriffs to make complaint of all violations of the criminal law, which shall come to their knowledge, within their respective jurisdictions.
[ 1963 c 4 s 36.28.011. Prior: 1955 c 10 s 1. Cf. Code 1881 s 2801, part; 1869 p 264 s 311, part; RRS s 4173, part.]
Notes of Decisions
Cited in 7 cases (6 in the last 5 years), 1963–2024 · leading case: State v. Twitchell, 378 P.2d 444 (Wash. 1963).
State v. Twitchell, 378 P.2d 444 (Wash. 1963). · cites it 2× “010 (1) and (6), and RCW 36.28.011. His brief, under the second heading, contains an excellent discussion of the applicable criminal law, and some that is inapplicable, but the only portion of it which is directed to the question whether the evidence was sufficient to support…”
In re Recall of Fortney, 478 P.3d 1061 (Wash. 2021). “Adam Fortney violated his statutory duties under RCW 36.28.011 and/or 36.28.020 and exercised discretion in a manifestly unreasonable manner by making a public statement on March 27, 2020 that absolved a deputy sheriff of asserted wrongdoing for tackling a black woman related to…”
In Re Recall of Snaza, 480 P.3d 404 (Wash. 2021). “” RCW 36.28.011; RCW 43.20.050(5). Further, he points out that Snaza is bound by his oath of office to uphold the law.”
In re Recall of Fortney, 503 P.3d 556 (Wash. 2022). “010, and exercised discretion in a manifestly unreasonable manner by rehiring three deputy sheriffs previously discharged following investigation and findings of misconduct; and 4.”
In re Recall of Weyrich, 554 P.3d 1202 (Wash. 2024). · cites it 5× “In September 2022, Sheriff McDermott violated RCW 36.28.011 by refusing to accept criminal complaints against Skagit County officials; 2.”
Hart v. McDermott (W.D. Wash. 2023). · cites it 2× “First, they allege that McDermott 23 violated RCW 36.28.011 by failing to “make complaint [sic] of violations of the criminal law 24 1 submitted to him.”
In re Recall of Hatcher, 478 P.3d 1077 (Wash. 2021). “” Further, under RCW 36.28.011, “[i]n addition to the duties contained in RCW 36.”
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