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

Wash. Rev. Code § 4.16.100 (2026)

Actions limited to two years

✓ current as of May 2026
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Within two years:
(1) An action for libel, slander, assault, assault and battery, or false imprisonment.
(2) An action upon a statute for a forfeiture or penalty to the state.
[Code 1881 s 29; 1877 p 8 s 29; 1869 p 9 s 29; 1854 p 363 s 5; RRS s 160.]

Notes:

Limitation of action for recovery of transportation charges: RCW 81.28.270.
Notes of Decisions
Cited in 109 cases (41 in the last 5 years), 1960–2026 · leading case: U. S. Oil & Refining Co. v. Dep't of Ecology, 633 P.2d 1329 (Wash. 1981).
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U. S. Oil & Refining Co. v. Dep't of Ecology, 633 P.2d 1329 (Wash. 1981). · cites it 22× “Oil contested the penalties regarding 6 days in 1975, on the ground that they were barred by the 2-year statute of limitation in RCW 4.16.100(2). The penalties were affirmed upon successive appeals to DOE's assistant director, the Pollution Control Hearing Board, and the…”
Dezmond Emeson, V Dept. Of Corr., 376 P.3d 430 (Wash. Ct. App. 2016). · cites it 4× “DOC argues the two-year statute of limitations applies for two reasons: first, because “[i]n-vasion of privacy by intrusion is an intentional act” and “[i]ntentional torts are subject to a two[-]year statute of limitations” under RCW 4.”
State Farm Fire & Cas. Co. v. William D. Morgan, 199 Wash. App. 435 (Wash. Ct. App. 2017). · cites it 5× “at 5; RCW 4.16.100(1); Heckart v. City of Yakima, 42 Wn.”
Eastwood v. Cascade Broad. Co., 722 P.2d 1295 (Wash. 1986). · cites it 5× “Plaintiffs thereupon acknowledged that the defamation action was barred by the 2-year libel and slander statute of limitations (RCW 4.16.100), but moved for partial summary judgment on the statute of limitations defense on the ground that the 3-year tort statute of limitations…”
LaMon v. Butler, 770 P.2d 1027 (Wash. 1989). · cites it 2× “See RCW 4.16.100(1). The April 1980 article contains the same misstatement that appeared in the September 1979 article.”
St. Michelle v. Robinson, 759 P.2d 467 (Wash. Ct. App. 1988). · cites it 3× “The 2-year statute of limitations, RCW 4.16.100, provides in part: Within two years: (1) An action for libel, slander, assault, assault and battery, or false imprisonment.”
Denise Reagan, V St. Elmo Newton, Iii, Md, 436 P.3d 411 (Wash. Ct. App. 2019). “RCW 4.16.100(1). Reagan alleges that she was injured on May 13, 2014.”
Nims v. Bd. of Reg. for Prof'l Engineers & Land Surveyors, 53 P.3d 52 (Wash. Ct. App. 2002). · cites it 2× “In that judgment, which was not appealed, the superior court held that disciplinary proceedings against a land surveyor are subject to the two-year statute of limitations set forth in RCW 4.16.100(2). 23 As a matter of public policy, collateral estoppel prevents the relitigation…”
French v. Uribe, Inc., 130 P.3d 370 (Wash. Ct. App. 2006). · cites it 4× “, argues that the two-year statute of limitations found in RCW 4.16.100 applies to cases brought pursuant to RCW 51.”
Ziegler v. Ziegler, 28 F. Supp. 2d 601 (E.D. Wash. 1998). · cites it 4× “There is no allegation within the statute of limitations of actual battery. On or about December 4, 1995, however, the Defendant communicated to the Plaintiff he was waiting for her at home with a loaded shotgun.”
Heckart v. City of Yakima, 708 P.2d 407 (Wash. Ct. App. 1985). · cites it 2× “Both the Superior Court, and the Commissioner of this court on a motion on the merits, applied RCW 4.16.100(1), which establishes a 2-year limitation period for: "an action for libel, slander, assault, assault and battery, or false imprisonment.”
Stansfield v. Douglas Cnty., 146 Wash. 2d 116 (Wash. 2002). “080(2) (three year limitation on general tort claims); RCW 4.16.100(1) (two year limitation on libel, slander, and false imprisonment).”
Show all 109 citing cases →
— Wash. Rev. Code § 4.16.100(1) — 53 cases
State Farm Fire & Cas. Co. v. William D. Morgan, 199 Wash. App. 435 (Wash. Ct. App. 2017). “at 5; RCW 4.16.100(1); Heckart v. City of Yakima, 42 Wn.”
LaMon v. Butler, 770 P.2d 1027 (Wash. 1989). “See RCW 4.16.100(1). The April 1980 article contains the same misstatement that appeared in the September 1979 article.”
Dezmond Emeson, V Dept. Of Corr., 376 P.3d 430 (Wash. Ct. App. 2016). “DOC argues the two-year statute of limitations applies for two reasons: first, because “[i]n-vasion of privacy by intrusion is an intentional act” and “[i]ntentional torts are subject to a two[-]year statute of limitations” under RCW 4.”
Denise Reagan, V St. Elmo Newton, Iii, Md, 436 P.3d 411 (Wash. Ct. App. 2019). “RCW 4.16.100(1). Reagan alleges that she was injured on May 13, 2014.”
Eastwood v. Cascade Broad. Co., 722 P.2d 1295 (Wash. 1986). “Plaintiffs thereupon acknowledged that the defamation action was barred by the 2-year libel and slander statute of limitations (RCW 4.16.100), but moved for partial summary judgment on the statute of limitations defense on the ground that the 3-year tort statute of limitations…”
— Wash. Rev. Code § 4.16.100(2) — 6 cases
U. S. Oil & Refining Co. v. Dep't of Ecology, 633 P.2d 1329 (Wash. 1981). “Oil contested the penalties regarding 6 days in 1975, on the ground that they were barred by the 2-year statute of limitation in RCW 4.16.100(2). The penalties were affirmed upon successive appeals to DOE's assistant director, the Pollution Control Hearing Board, and the…”
Nims v. Bd. of Reg. for Prof'l Engineers & Land Surveyors, 53 P.3d 52 (Wash. Ct. App. 2002). “In that judgment, which was not appealed, the superior court held that disciplinary proceedings against a land surveyor are subject to the two-year statute of limitations set forth in RCW 4.16.100(2). 23 As a matter of public policy, collateral estoppel prevents the relitigation…”
U. S. Oil & Refining Co. v. Dep't of Ecology, 615 P.2d 1340 (Wash. Ct. App. 1980).
Nims v. Wa. Bd. of Reg., 53 P.3d 52 (Wash. Ct. App. 2002).
Mark Marlow, et ux v. Douglas Cnty. (Wash. Ct. App. 2013).
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