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

Wash. Rev. Code § 4.16.080 (2026)

Actions limited to three years

✓ current as of May 2026
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The following actions shall be commenced within three years:
(1) An action for waste or trespass upon real property;
(2) An action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof, or for any other injury to the person or rights of another not hereinafter enumerated;
(3) Except as provided in RCW 4.16.040(2), an action upon a contract or liability, express or implied, which is not in writing, and does not arise out of any written instrument;
(4) An action for relief upon the ground of fraud, the cause of action in such case not to be deemed to have accrued until the discovery by the aggrieved party of the facts constituting the fraud;
(5) An action against a sheriff, coroner, or constable upon a liability incurred by the doing of an act in his or her official capacity and by virtue of his or her office, or by the omission of an official duty, including the nonpayment of money collected upon an execution; but this subsection shall not apply to action for an escape;
(6) An action against an officer charged with misappropriation or a failure to properly account for public funds intrusted to his or her custody; an action upon a statute for penalty or forfeiture, where an action is given to the party aggrieved, or to such party and the state, except when the statute imposing it prescribed a different limitation: PROVIDED, HOWEVER, The cause of action for such misappropriation, penalty, or forfeiture, whether for acts heretofore or hereafter done, and regardless of lapse of time or existing statutes of limitations, or the bar thereof, even though complete, shall not be deemed to accrue or to have accrued until discovery by the aggrieved party of the act or acts from which such liability has arisen or shall arise, and such liability, whether for acts heretofore or hereafter done, and regardless of lapse of time or existing statute of limitation, or the bar thereof, even though complete, shall exist and be enforceable for three years after discovery by aggrieved party of the act or acts from which such liability has arisen or shall arise.
[ 2011 c 336 s 83; 1989 c 38 s 2; 1937 c 127 s 1; 1923 c 28 s 1; Code 1881 s 28; 1869 p 8 s 28; 1854 p 363 s 4; RRS s 159.]

Notes:

Reviser's note: Transitional proviso omitted from subsection (6). The proviso reads: "PROVIDED, FURTHER, That no action heretofore barred under the provisions of this paragraph shall be commenced after ninety days from the time this act becomes effective;".
Notes of Decisions
Cited in 931 cases (228 in the last 5 years), 1952–2026 · leading case: Fast v. Kennewick Pub. Hosp. Dist., 384 P.3d 232 (Wash. 2016).
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Fast v. Kennewick Pub. Hosp. Dist., 384 P.3d 232 (Wash. 2016). · cites it 16× “¶23 RCW 4.16.080, in applicable part, states, The following actions shall be commenced within three years: (2) An action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof, or for any other injury to the person or rights…”
Tingey v. Haisch, 152 P.3d 1020 (Wash. 2007). · cites it 12× “I am of the view and agree with the Court of Appeals that such "open" accounts are what the legislature had in mind when amending RCW 4.16.080. ¶ 40 Despite the legislative history which indicates the legislature, wisely I believe, intended that account receivable under this…”
Tingey v. Haisch, 159 Wash. 2d 652 (Wash. 2007). · cites it 12× “I am of the view and agree with the Court of Appeals that such “open” accounts are what the legislature had in mind when amending RCW 4.16.080. ¶40 Despite the legislative history which indicates the legislature, wisely I believe, intended that “account receivable” under this…”
Young v. Est. of Snell, 948 P.2d 1291 (Wash. 1997). · cites it 17× “011 be subject to the three-year statute of limitations set forth in RCW 4.16.080. Upholding the superior court’s order, the Estate argues, would bring about the unlikely and absurd result that there would be no time limitation on claims against the estate of an alleged…”
Robinson v. City of Seattle, 830 P.2d 318 (Wash. 1992). · cites it 7× “6(d) (Release 2 1989); see also Kibble-Smith, Statutes of Limitation and Section 1983: Implications for Illinois Civil Rights Law, 20 J.”
Seattle Prof'l Eng'g Employees Ass'n v. Boeing Co., 991 P.2d 1126 (Wash. 2000). · cites it 10× “The employees argue the three-year statute of limitations of RCW 4.16.080(2) applies. Boeing contends an action under the WMWA is subject to the two-year catch-all statute of limitations provided under RCW 4.”
Silver v. Rudeen Mgmt. Co., Inc., 484 P.3d 1251 (Wash. 2021). · cites it 7× “We are asked to determine the applicable statute of limitations for such an action. We hold that a tenant’s action under RCW 59.”
U. S. Oil & Refining Co. v. Dep't of Ecology, 633 P.2d 1329 (Wash. 1981). · cites it 10× “As the majority points out, RCW 4.16.080 in some circumstances provides for a discovery rule but not in the situation before us.”
Shepard v. Holmes, 345 P.3d 786 (Wash. Ct. App. 2014). · cites it 6× “She argues that the court erred or abused its discretion in (1) concluding that her misrepresentation and CPA claims were time barred, (2) concluding that her original claim did not sufficiently plead a contract claim against Sun River, (3) denying her leave to amend her…”
First Maryland Leasecorp v. Rothstein, 864 P.2d 17 (Wash. Ct. App. 1993). · cites it 11× “RCW 4.16.080(4). However, the cause of action is "not to be deemed to have accrued until the discovery by the *282 aggrieved party of the facts constituting the fraud".”
Henderson Homes, Inc. v. City of Bothell, 877 P.2d 176 (Wash. 1994). · cites it 8× “If such amounts can be determined, the court shall refund the misspent portions in accordance with the terms of RCW 82.02.020. If proper accounting cannot be made, I would direct the trial court to order a refund of $400 per lot, according to the number of lots still owned by…”
Hudson v. Condon, 6 P.3d 615 (Wash. Ct. App. 2000). · cites it 9× “" RCW 4.16.080 imposes a three-year limitation for actions involving conversion, tort or relief based on fraud.”
Show all 931 citing cases →
— Wash. Rev. Code § 4.16.080(1) — 26 cases
Wallace v. Lewis Cnty., 137 P.3d 101 (Wash. Ct. App. 2006).
Wallace v. Lewis Cnty., 134 Wash. App. 1 (Wash. Ct. App. 2006).
New Meadows Holding Co. v. Washington Water Power Co., 659 P.2d 1113 (Wash. Ct. App. 1983).
Bradley v. Am. Smelting & Refining Co., 709 P.2d 782 (Wash. 1985).
New Meadows Holding Co. v. Washington Water Power Co., 687 P.2d 212 (Wash. 1984).
— Wash. Rev. Code § 4.16.080(17) — 1 case
Lafawnda Williams v. Matthew Mccandlis (Wash. Ct. App. 2020).
— Wash. Rev. Code § 4.16.080(2) — 450 cases
Fast v. Kennewick Pub. Hosp. Dist., 384 P.3d 232 (Wash. 2016). “¶23 RCW 4.16.080, in applicable part, states, The following actions shall be commenced within three years: (2) An action for taking, detaining, or injuring personal property, including an action for the specific recovery thereof, or for any other injury to the person or rights…”
Silver v. Rudeen Mgmt. Co., Inc., 484 P.3d 1251 (Wash. 2021). “We are asked to determine the applicable statute of limitations for such an action. We hold that a tenant’s action under RCW 59.”
Seattle Prof'l Eng'g Employees Ass'n v. Boeing Co., 991 P.2d 1126 (Wash. 2000). “The employees argue the three-year statute of limitations of RCW 4.16.080(2) applies. Boeing contends an action under the WMWA is subject to the two-year catch-all statute of limitations provided under RCW 4.”
Young v. Est. of Snell, 948 P.2d 1291 (Wash. 1997). “011 be subject to the three-year statute of limitations set forth in RCW 4.16.080. Upholding the superior court’s order, the Estate argues, would bring about the unlikely and absurd result that there would be no time limitation on claims against the estate of an alleged…”
Antonius v. King Cnty., 103 P.3d 729 (Wash. 2004).
— Wash. Rev. Code § 4.16.080(3) — 161 cases
Tingey v. Haisch, 152 P.3d 1020 (Wash. 2007). “I am of the view and agree with the Court of Appeals that such "open" accounts are what the legislature had in mind when amending RCW 4.16.080. ¶ 40 Despite the legislative history which indicates the legislature, wisely I believe, intended that account receivable under this…”
Tingey v. Haisch, 159 Wash. 2d 652 (Wash. 2007). “I am of the view and agree with the Court of Appeals that such “open” accounts are what the legislature had in mind when amending RCW 4.16.080. ¶40 Despite the legislative history which indicates the legislature, wisely I believe, intended that “account receivable” under this…”
Robinson v. City of Seattle, 830 P.2d 318 (Wash. 1992). “6(d) (Release 2 1989); see also Kibble-Smith, Statutes of Limitation and Section 1983: Implications for Illinois Civil Rights Law, 20 J.”
James v. Cnty. of Kitsap, 115 P.3d 286 (Wash. 2005).
James v. Kitsap Cnty., 154 Wash. 2d 574 (Wash. 2005).
— Wash. Rev. Code § 4.16.080(4) — 102 cases
Shepard v. Holmes, 345 P.3d 786 (Wash. Ct. App. 2014). “She argues that the court erred or abused its discretion in (1) concluding that her misrepresentation and CPA claims were time barred, (2) concluding that her original claim did not sufficiently plead a contract claim against Sun River, (3) denying her leave to amend her…”
First Maryland Leasecorp v. Rothstein, 864 P.2d 17 (Wash. Ct. App. 1993). “RCW 4.16.080(4). However, the cause of action is "not to be deemed to have accrued until the discovery by the *282 aggrieved party of the facts constituting the fraud".”
Crisman v. Crisman, 931 P.2d 163 (Wash. Ct. App. 1997).
Crisman v. Crisman, 931 P.2d 163 (Wash. Ct. App. 1997).
Hudson v. Condon, 6 P.3d 615 (Wash. Ct. App. 2000). “" RCW 4.16.080 imposes a three-year limitation for actions involving conversion, tort or relief based on fraud.”
— Wash. Rev. Code § 4.16.080(5) — 2 cases
Thompson v. Wilson, 175 P.3d 1149 (Wash. Ct. App. 2008).
Thompson v. Wilson, 142 Wash. App. 803 (Wash. Ct. App. 2008).
— Wash. Rev. Code § 4.16.080(6) — 5 cases
U. S. Oil & Refining Co. v. Dep't of Ecology, 633 P.2d 1329 (Wash. 1981). “As the majority points out, RCW 4.16.080 in some circumstances provides for a discovery rule but not in the situation before us.”
State v. O'connell, 523 P.2d 872 (Wash. 1974).
Lane v. City of Seattle, 194 P.3d 977 (Wash. 2008).
Lane v. City of Seattle, 164 Wash. 2d 875 (Wash. 2008).
U. S. Oil & Refining Co. v. Dep't of Ecology, 615 P.2d 1340 (Wash. Ct. App. 1980).
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