Wash. Rev. Code » Title 4 · Chapter 4.12
Revised Code of Washington

Wash. Rev. Code § 4.12.010 (2026)

Actions to be commenced where subject is situated

✓ current as of May 2026
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Actions for the following causes shall be commenced in the county in which the subject of the action, or some part thereof, is situated:
(1) For the recovery of, for the possession of, for the partition of, for the foreclosure of a mortgage on, or for the determination of all questions affecting the title, or for any injuries to real property.
(2) All questions involving the rights to the possession or title to any specific article of personal property, in which last mentioned class of cases, damages may also be awarded for the detention and for injury to such personal property.
[Code 1881 s 47; 1877 p 11 s 48; 1869 p 12 s 48; 1860 p 7 s 15; 1854 p 133 s 13; RRS s 204.]
Notes of Decisions
Cited in 32 cases (4 in the last 5 years), 1953–2025 · leading case: Ralph v. Dep't of Nat. Resources, 343 P.3d 342 (Wash. 2014).
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Ralph v. Dep't of Nat. Resources, 343 P.3d 342 (Wash. 2014). · cites it 74× “At issue is the distinction between venue and jurisdiction, in the context of a statute providing that actions “for any injuries to real property” “shall be commenced” in the county in which the property is located.”
Ralph v. Weyerhaeuser Co., 386 P.3d 721 (Wash. 2016). · cites it 31× “A majority of this court held that “RCW 4.12.010 relates to venue, not jurisdiction,” and therefore “reverse [d] and remand [ed] for further proceedings.”
Ralph v. Dep't of Nat. Resources, 286 P.3d 992 (Wash. Ct. App. 2012). · cites it 23× “Because Washington Supreme Court precedent interprets RCW 4.12.010 as jurisdictional, the trial court was required to dismiss, and we affirm.”
Washington State Bank v. Medalia Healthcare L.L.C., 984 P.2d 1041 (Wash. Ct. App. 1999). · cites it 15× “185? We hold that: (1) Pierce County had subject matter jurisdiction because a conversion action for monetary recovery is transitory in nature and not subject to RCW 4.12.010 requirements; (2) Medalia committed conversion not by simply purchasing the encumbered collateral but by…”
Lakeside Indus. v. Thurston Cnty., 83 P.3d 433 (Wash. Ct. App. 2004). · cites it 5× “Friends and the Nisqually Tribe also moved to dismiss or change venue, claiming Mason County Superior Court lacked jurisdiction to hear Lakeside’s LUPA petition based on article IV, section 6 of the Washington Constitution 2 and RCW 4.12.010. The Mason County Superior Court…”
Five Corners Fam. Farmers v. State, 268 P.3d 892 (Wash. 2011). · cites it 3× “*315 ¶31 Though Easterday does not advance the argument before this court, the trial court also appears to have relied on RCW 4.12.010 to support its decision to change venue.”
Lakeside Indus. v. Thurston Cnty., 83 P.3d 433 (Wash. Ct. App. 2004). · cites it 5× “Friends and the Nisqually Tribe also moved to dismiss or change venue, claiming Mason *437 County Superior Court lacked jurisdiction to hear Lakeside's LUPA petition based on article IV, section 6 of the Washington Constitution and RCW 4.12.010. [2] The Mason County Superior…”
Snyder v. Ingram, 296 P.2d 305 (Wash. 1956). · cites it 7× “Defendants appeared specially and moved for dismissal of the action on the ground that, under RCW 4.12.010 (2), the King county court had no jurisdiction because the automobile, the subject matter of the action, was located in Chelan county at the time of the commencement of the…”
N. Com. Co. v. E. J. Hermann Co., 593 P.2d 1332 (Wash. Ct. App. 1979). · cites it 2× “[7] NC also contended that the trial court lacked jurisdictional authority to grant Bernadine's petition to set aside the sale, on the basis of the venue requirements of RCW 4.12.010 and .020(2). Bernadine's motion was to vacate a judgment and did not commence a new action.”
Washington State Bank v. MEDALIA, 984 P.2d 1041 (Wash. Ct. App. 1999). · cites it 14× “185? We hold that: (1) Pierce County had subject matter jurisdiction because a conversion action for monetary recovery is transitory in nature and not subject to RCW 4.12.010 requirements; (2) Medalia committed conversion not by simply purchasing the encumbered collateral but by…”
MacKenzie v. Barthol, 173 P.3d 980 (Wash. Ct. App. 2007). “RCW 4.12.010(1). Despite this, our Supreme Court has held that "an action to establish and enforce a trust in real property[, as ordered by the B.”
MacKenzie v. Barthol, 142 Wash. App. 235 (Wash. Ct. App. 2007). “RCW 4.12.010(1). Despite this, our Supreme Court has held that “an action to establish and enforce a trust in real property!, as ordered by the B.”
Show all 32 citing cases →
— Wash. Rev. Code § 4.12.010(1) — 20 cases
Ralph v. Weyerhaeuser Co., 386 P.3d 721 (Wash. 2016). “A majority of this court held that “RCW 4.12.010 relates to venue, not jurisdiction,” and therefore “reverse [d] and remand [ed] for further proceedings.”
Ralph v. Dep't of Nat. Resources, 343 P.3d 342 (Wash. 2014). “At issue is the distinction between venue and jurisdiction, in the context of a statute providing that actions “for any injuries to real property” “shall be commenced” in the county in which the property is located.”
Washington State Bank v. Medalia Healthcare L.L.C., 984 P.2d 1041 (Wash. Ct. App. 1999). “185? We hold that: (1) Pierce County had subject matter jurisdiction because a conversion action for monetary recovery is transitory in nature and not subject to RCW 4.12.010 requirements; (2) Medalia committed conversion not by simply purchasing the encumbered collateral but by…”
Lakeside Indus. v. Thurston Cnty., 83 P.3d 433 (Wash. Ct. App. 2004). “Friends and the Nisqually Tribe also moved to dismiss or change venue, claiming Mason County Superior Court lacked jurisdiction to hear Lakeside’s LUPA petition based on article IV, section 6 of the Washington Constitution 2 and RCW 4.12.010. The Mason County Superior Court…”
Ralph v. Dep't of Nat. Resources, 286 P.3d 992 (Wash. Ct. App. 2012). “Because Washington Supreme Court precedent interprets RCW 4.12.010 as jurisdictional, the trial court was required to dismiss, and we affirm.”
— Wash. Rev. Code § 4.12.010(2) — 6 cases
Washington State Bank v. Medalia Healthcare L.L.C., 984 P.2d 1041 (Wash. Ct. App. 1999). “185? We hold that: (1) Pierce County had subject matter jurisdiction because a conversion action for monetary recovery is transitory in nature and not subject to RCW 4.12.010 requirements; (2) Medalia committed conversion not by simply purchasing the encumbered collateral but by…”
Ralph v. Dep't of Nat. Resources, 286 P.3d 992 (Wash. Ct. App. 2012). “Because Washington Supreme Court precedent interprets RCW 4.12.010 as jurisdictional, the trial court was required to dismiss, and we affirm.”
Ralph v. Dep't of Nat. Resources, 343 P.3d 342 (Wash. 2014). “At issue is the distinction between venue and jurisdiction, in the context of a statute providing that actions “for any injuries to real property” “shall be commenced” in the county in which the property is located.”
Washington State Bank v. MEDALIA, 984 P.2d 1041 (Wash. Ct. App. 1999). “185? We hold that: (1) Pierce County had subject matter jurisdiction because a conversion action for monetary recovery is transitory in nature and not subject to RCW 4.12.010 requirements; (2) Medalia committed conversion not by simply purchasing the encumbered collateral but by…”
Corning & Sons, Inc. v. McNamara, 506 P.2d 1328 (Wash. Ct. App. 1973).
— Wash. Rev. Code § 4.12.010(l) — 1 case
Ralph v. Weyerhaeuser Co., 386 P.3d 721 (Wash. 2016). “A majority of this court held that “RCW 4.12.010 relates to venue, not jurisdiction,” and therefore “reverse [d] and remand [ed] for further proceedings.”
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