Revised Code of Washington
Wash. Rev. Code § 36.45.010 (2026)
Manner of filing
✓ current as of May 2026
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All claims for damages against any county shall be filed in the manner set forth in chapter 4.96 RCW.
[ 1993 c 449 s 10; 1967 c 164 s 14; 1963 c 4 s 36.45.010. Prior: 1957 c 224 s 7; prior: 1919 c 149 s 1, part; RRS s 4077, part.]
Notes:
Purpose—Severability—1993 c 449: See notes following RCW 4.96.010.
Severability—Purpose—1967 c 164: See notes following RCW 4.96.010.
Tortious conduct of political subdivisions and municipal corporations, liability for damages: Chapter 4.96 RCW.
Notes of Decisions
Cited in 23
cases, 1963–2010 · leading case: Int'l Ass'n of Fire Fighters, Local 46 v. City of Everett, 42 P.3d 1265 (Wash. 2002).
Int'l Ass'n of Fire Fighters, Local 46 v. City of Everett, 42 P.3d 1265 (Wash. 2002). “In Thorgaard, this court examined whether the former county nonclaim statutes, RCW 36.45.010 and .030, which required a party to file a claim with the board of county commissioners before an action for damages could be sought, also required a party to file a claim before…”
Thorgaard Plumbing & Heating Co., Inc. v. Cnty. of King, 426 P.2d 828 (Wash. 1967). “It alleged that Thorgaard had failed to file a written claim with the Board of County Commissioners within 90 days of the damage occurring, as required by RCW 36.45.010. The trial court denied the County’s motions, confirmed the arbitration award and granted Thorgaard a judgment…”
Champagne v. Thurston Cnty., 134 Wash. App. 515 (Wash. Ct. App. 2006). “The Corrections Officers assert that the trial *517 court erred in granting the County’s motion for summary judgment, based on their failure to file a notice of claim with the County under RCW 36.45.010. They argue that their claims are statutorily based and, therefore, are not…”
Champagne v. Thurston Cnty., 141 P.3d 72 (Wash. Ct. App. 2006). “The Correction Officers assert that the trial court erred in granting the County's motion for summary judgment, based on their failure to file a notice of claim with the County under RCW 36.45.010. They argue that their claims are statutorily based and, therefore, are not…”
Hall v. Niemer, 649 P.2d 98 (Wash. 2009). “45 also contains such a requirement (RCW 36.45.010) as well as the 3-month provision found unconstitutional in Jenkins .”
Champagne v. Thurston Cnty., 178 P.3d 936 (Wash. 2008). “¶ 5 The County moved for summary judgment arguing that Champagne failed to meet the "condition precedent" of filing the claim with the County pursuant to RCW 36.45.010 and chapter 4.96 RCW (hereinafter collectively referred to as nonclaim statutes).”
Davidson v. Hensen, 954 P.2d 1327 (Wash. 1998). “We stated: The fact that a party to the arbitration may apply to the court for confirmation of the award is not to be equated with the bringing of an action for the collection of compensation, within the meaning of RCW 36.45.010. It is no more than a motion for an order to…”
Davidson v. Hensen, 135 Wash. 2d 112 (Wash. 1998). “We stated: The fact that a party to the arbitration may apply to the court for confirmation of the award is not to be equated with the bringing of an action for the collection of compensation, within the meaning of RCW 36.45.010. It is no more than a motion for an order to…”
Broom v. Morgan Stanley DW Inc., 236 P.3d 182 (Wash. 2010). “In Thorgaard, we considered the purposes of the former county nonclaim statute, RCW 36.45.010intended to put the county on notice of an impending actionand the WAA, former chapter 7.”
Broom v. Morgan Stanley DW, Inc., 169 Wash. 2d 231 (Wash. 2010). “In Thorgaard, we considered the purposes of the former county nonclaim statute, RCW 36.45.010 — intended to put the county on notice of an impending action — and the WAA, former chapter 7.”
Cook v. State, 521 P.2d 725 (Wash. 1974). “040 (charter and noncharter cities); RCW 36.45.010 (counties); RCW 38.52.205 (civil defense related activities); RCW 47.”
Olson v. King Cnty., 428 P.2d 562 (Wash. 1967). “80, and his judgment was for $1,500; Handley’s claim mentions dollar damages of only $150 (but his damages, as shown by the claim, were considerably more than that),1 and his judgment was for $1,000. It should be noted that the Olson claim was the only one which included a…”
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