Wash. Rev. Code » Title 4 · Chapter 4.16
Revised Code of Washington

Wash. Rev. Code § 4.16.040 (2026)

Actions limited to six years

✓ current as of May 2026
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The following actions shall be commenced within six years:
(1) An action upon a contract in writing, or liability express or implied arising out of a written agreement, except as provided for in RCW 64.04.007(2).
(2) An action upon an account receivable. For purposes of this section, an account receivable is any obligation for payment incurred in the ordinary course of the claimant's business or profession, whether arising from one or more transactions and whether or not earned by performance.
(3) An action for the rents and profits or for the use and occupation of real estate.
[ 2012 c 185 s 3; 2007 c 124 s 1; 1989 c 38 s 1; 1980 c 105 s 2; 1927 c 137 s 1; Code 1881 s 27; 1854 p 363 s 3; RRS s 157.]

Notes:

Application—2007 c 124: "This act applies to all causes of action on accounts receivable, whether commenced before or after July 22, 2007." [ 2007 c 124 s 2.]
Application—1980 c 105: See note following RCW 4.16.020.
Notes of Decisions
Cited in 306 cases (50 in the last 5 years), 1952–2026 · leading case: Tingey v. Haisch, 152 P.3d 1020 (Wash. 2007).
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Tingey v. Haisch, 152 P.3d 1020 (Wash. 2007). · cites it 30× “In 1989 the legislature amended RCW 4.16.040, the six-year statute of limitations, adding as a new category, "action[s] upon an account receivable incurred in the ordinary course of business.”
Tingey v. Haisch, 159 Wash. 2d 652 (Wash. 2007). · cites it 28× “In 1989, the legislature amended RCW 4.16.040, the six-year statute of limitations, adding as a new category “action [s] upon an.”
DePhillips v. Zolt Constr. Co., 136 Wash. 2d 26 (Wash. 1998). · cites it 9× “RCW 4.16.040(1). The trial court granted summary judgment in favor of Zolt and dismissed the action as untimely.”
DePhillips v. Zolt Const. Co., 959 P.2d 1104 (Wash. 1998). · cites it 9× “RCW 4.16.040(1). The trial court granted summary judgment in favor of Zolt and dismissed the action as untimely.”
Bogle & Gates, P.L.L.C. v. Holly Mountain Resources, 32 P.3d 1002 (Wash. Ct. App. 2001). · cites it 7× “The trial court concluded that the three-year statute, rather than the six-year statute (RCW 4.16.040(1)), governed, and thus dismissed the action against Holly *560 Mountain Resources.”
1000 Virginia Ltd. P'ship v. Vertecs Corp., 146 P.3d 423 (Wash. 2006). · cites it 3× “RCW 4.16.040. The statute of limitations bars the plaintiff from bringing an action in court after the specified time.”
1000 Virginia Ltd. P'ship v. Vertecs Corp., 158 Wash. 2d 566 (Wash. 2006). · cites it 3× “RCW 4.16.040. The statute of limitations bars the plaintiff from bringing an action in court after the specified time.”
Harmony at Madrona Park Owners Ass'n v. Madison Harmony Dev., Inc., 143 Wash. App. 345 (Wash. Ct. App. 2008). · cites it 6× “310 is a pure statute of repose, is distinct from the applicable statute of limitations, and does not define when a breach of contract claim accrues for purposes of the statute of limitations.”
Tingey v. Haisch, 117 P.3d 1189 (Wash. Ct. App. 2005). · cites it 14× “We conclude that the term “account receivable” as used in RCW 4.16.040 is ambiguous and requires interpretation.”
Parker Estates, Bluestone, Hockley, V William & Lesley Pattison, 391 P.3d 481 (Wash. Ct. App. 2016). · cites it 4× “1 ¶17 PEHA and Bluestone argue that the statute of limitations provision in RCW 4.16.040(1) prevents the Pattisons’ challenge to the validity of Bylaw 6.”
Cambridge Townhomes v. Pac. Star Roofing, 209 P.3d 863 (Wash. 2009). · cites it 3× “Under RCW 4.16.040, an action upon a contract in writing must be commenced within six years.”
Cambridge Townhomes, LLC v. Pac. Star Roofing, Inc., 166 Wash. 2d 475 (Wash. 2009). · cites it 3× “Generally, a statute of limitation runs from the time a claim accrues; a claim accrues when a party has the right to apply to a court for relief, which may be at the time the claim is discovered.”
Show all 306 citing cases →
— Wash. Rev. Code § 4.16.040(1) — 142 cases
DePhillips v. Zolt Constr. Co., 136 Wash. 2d 26 (Wash. 1998). “RCW 4.16.040(1). The trial court granted summary judgment in favor of Zolt and dismissed the action as untimely.”
DePhillips v. Zolt Const. Co., 959 P.2d 1104 (Wash. 1998). “RCW 4.16.040(1). The trial court granted summary judgment in favor of Zolt and dismissed the action as untimely.”
Bogle & Gates, P.L.L.C. v. Holly Mountain Resources, 32 P.3d 1002 (Wash. Ct. App. 2001). “The trial court concluded that the three-year statute, rather than the six-year statute (RCW 4.16.040(1)), governed, and thus dismissed the action against Holly *560 Mountain Resources.”
1000 Virginia Ltd. P'ship v. Vertecs Corp., 146 P.3d 423 (Wash. 2006). “RCW 4.16.040. The statute of limitations bars the plaintiff from bringing an action in court after the specified time.”
1000 Virginia Ltd. P'ship v. Vertecs Corp., 158 Wash. 2d 566 (Wash. 2006). “RCW 4.16.040. The statute of limitations bars the plaintiff from bringing an action in court after the specified time.”
— Wash. Rev. Code § 4.16.040(2) — 28 cases
Tingey v. Haisch, 152 P.3d 1020 (Wash. 2007). “In 1989 the legislature amended RCW 4.16.040, the six-year statute of limitations, adding as a new category, "action[s] upon an account receivable incurred in the ordinary course of business.”
Tingey v. Haisch, 159 Wash. 2d 652 (Wash. 2007). “In 1989, the legislature amended RCW 4.16.040, the six-year statute of limitations, adding as a new category “action [s] upon an.”
Tingey v. Haisch, 117 P.3d 1189 (Wash. Ct. App. 2005). “We conclude that the term “account receivable” as used in RCW 4.16.040 is ambiguous and requires interpretation.”
Bogle & Gates, P.L.L.C. v. Holly Mountain Resources, 32 P.3d 1002 (Wash. Ct. App. 2001). “The trial court concluded that the three-year statute, rather than the six-year statute (RCW 4.16.040(1)), governed, and thus dismissed the action against Holly *560 Mountain Resources.”
Bogle & Gates, PLLC v. Zapel, 90 P.3d 703 (Wash. Ct. App. 2004).
— Wash. Rev. Code § 4.16.040(3) — 3 cases
Robinson v. City of Seattle, 830 P.2d 318 (Wash. 1992).
Shew v. Coon Bay Loafers, Inc., 455 P.2d 359 (Wash. 1969).
Liao Hua, V. Gang Yuan (Wash. Ct. App. 2026).
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