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

Wash. Rev. Code § 4.16.180 (2026)

Statute tolled by absence from state, concealment, etc

✓ current as of May 2026
Find cases: SyfertCases citing this section WA-LEGapp.leg.wa.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
If the cause of action shall accrue against any person who is a nonresident of this state, or who is a resident of this state and shall be out of the state, or concealed therein, such action may be commenced within the terms herein respectively limited after the coming, or return of such person into the state, or after the end of such concealment; and if after such cause of action shall have accrued, such person shall depart from and reside out of this state, or conceal himself or herself, the time of his or her absence or concealment shall not be deemed or taken as any part of the time limit for the commencement of such action.
[ 2011 c 336 s 84; 1927 c 132 s 1; Code 1881 s 36; 1854 p 364 s 10; RRS s 168.]
Notes of Decisions
Cited in 33 cases (4 in the last 5 years), 1964–2026 · leading case: Rodriguez v. James-Jackson, 111 P.3d 271 (Wash. Ct. App. 2005).
Sort: Relevance Newest Treatment
Rodriguez v. James-Jackson, 111 P.3d 271 (Wash. Ct. App. 2005). · cites it 4× “Here, Rodriguez asserts the statute of limitations was tolled under RCW 4.16.180. That statute states: If the cause of action shall accrue against any person who is a nonresident of this state, or who is a resident of this state and shall be out of the state, or concealed…”
Brown v. Pro West Transp. Ltd., 886 P.2d 223 (Wash. Ct. App. 1995). · cites it 8× “030, governing disclosure of information and reporting after an accident; because Santana, O’Neill, and Clark are not residents of this state and concealed their identities and locations in violation of RCW 4.16.180; and because of the operation of the discovery rule.”
Patrick v. DeYoung, 724 P.2d 1064 (Wash. Ct. App. 1986). · cites it 7× “II Tolling of the Statute of Limitations Patrick argues that the statute of limitations was tolled as to the DeYoungs under the provisions of RCW 4.16.180. We disagree. Pursuant to RCW 4.”
Caouette v. Martinez, 856 P.2d 725 (Wash. Ct. App. 1993). · cites it 6× “It also held that: the Martinezes "were 'concealing' themselves, as the term is used in RCW 4.16.180, following the automobile accident"; the "publication of the 'Order to Serve Amended Summons by Publication' did not give sufficient notice" to the Martinezes; and that the…”
Rodriguez v. James-Jackson, 127 Wash. App. 139 (Wash. Ct. App. 2005). · cites it 4× “Here, Rodriguez asserts the statute of limitations was tolled under RCW 4.16.180. That statute states: If the cause of action shall accrue against any person who is a nonresident of this state, or who is a resident of this state and shall be out of the state, or concealed…”
Duke v. Boyd, 942 P.2d 351 (Wash. 1997). · cites it 2× “, RCW 4.16.180 (time while person is concealed within or absent from the state is not considered part of the limitation period); RCW 4.”
Duke v. Boyd, 133 Wash. 2d 80 (Wash. 1997). · cites it 2× “, RCW 4.16.180 (time while person is concealed within or absent from the state is not considered part of the limitation period); RCW 4.”
Broad v. Mannesmann Anlagenbau, A.G., 10 P.3d 371 (Wash. 2000). · cites it 3× “In this case, the Ninth Circuit first suggests that the tolling provisions of RCW 4.16.180 might apply. Plaintiffs do not make this argument.”
Summerrise v. Stephens, 454 P.2d 224 (Wash. 1969). · cites it 5× “Quaere: Is an action for damages for a tort 1 committed in this state by a then resident of this state, who subsequently became a resident of another state, tolled by his absence from the state as provided in RCW 4.16.180 2 during a period when the plaintiff was aware of the…”
Martin v. Triol, 847 P.2d 471 (Wash. 1993). · cites it 2× “A potential defendant's absence from the state does not toll the statute of limitations under RCW 4.16.180 50 when the plaintiff has a statutory right, pursuant to RCW 46.”
Smith v. Forty Million, Inc., 395 P.2d 201 (Wash. 1964). · cites it 4× “Quaere: In an action for damages arising out of an automobile collision on a highway in this state is the statute of limitations tolled by the absence from the state of a nonresident defendant, as provided in RCW 4.16.180, 1 when the plaintiff has available to him at all times…”
Castro v. Stanwood Sch. Dist. No. 401, 151 Wash. 2d 221 (Wash. 2004). “See RCW 4.16.180 (“[T]he time of [defendant’s] absence or concealment shall not be deemed or taken as any part of the time limit for the commencement of such action.”
Show all 33 citing cases →
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.