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

Wash. Rev. Code § 4.16.200 (2026)

Statute tolled by death

✓ current as of May 2026
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Limitations on actions against a person who dies before the expiration of the time otherwise limited for commencement thereof are as set forth in chapter 11.40 RCW. Subject to the limitations on claims against a deceased person under chapter 11.40 RCW, if a person entitled to bring an action dies before the expiration of the time limited for the commencement thereof, and the cause of action survives, an action may be commenced by his or her representatives after the expiration of the time and within one year from his or her death.
[ 2011 c 336 s 85; 1989 c 333 s 8; Code 1881 s 38; 1877 p 9 s 38; 1854 p 364 s 12; RRS s 170.]

Notes:

Application—Effective date—1989 c 333: See note following RCW 11.40.010.
Decedents, claims against, time limits: RCW 11.40.051, 11.40.060.
Notes of Decisions
Cited in 18 cases (4 in the last 5 years), 1978–2025 · leading case: Young v. Est. of Snell, 948 P.2d 1291 (Wash. 1997).
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Young v. Est. of Snell, 948 P.2d 1291 (Wash. 1997). · cites it 18× “It states, in part, that ‘‘[¡limitations on actions against a person who dies before the expiration of the time otherwise limited for commencement thereof are as set forth in chapter 11.40 RCW.” Because Snell died prior to the expiration of the three-year statute of limitation…”
Wagg v. Est. of Dunham, 146 Wash. 2d 63 (Wash. 2002). · cites it 2× “200 specifies that “limitations on actions against a person who dies before the expiration of the time otherwise limited for commencement thereof are as set forth in chapter 11.40 RCW.” Creditor’s Claims—Against Estate Chapter 11.”
Wagg v. Est. of Dunham, 42 P.3d 968 (Wash. 2002). · cites it 2× “40 RCW." Creditor's Claims—Against Estate Chapter 11.”
Young v. Est. of Snell, 948 P.2d 1291 (Wash. 1998). · cites it 19× “[1] In a case where a putative defendant dies prior to the expiration of the applicable statute of limitations, RCW 4.16.200 comes into play. It states, in part, that "[l]imitations on actions against a person who dies before the expiration of the time otherwise limited for…”
Duke v. Boyd, 942 P.2d 351 (Wash. 1997). “190 (limitations tolled by minority, incompetency, disability, or imprisonment); RCW 4.16.200 (death of plaintiff or defendant); RCW 4.”
Duke v. Boyd, 133 Wash. 2d 80 (Wash. 1997). “190 (limitations tolled by minority, incompetency, disability, or imprisonment); RCW 4.16.200 (death of plaintiff or defendant); RCW 4.”
Hopper v. Hemphill, 575 P.2d 746 (Wash. Ct. App. 1978). · cites it 2× “RCW 4.16.200. 1 But here the statute did not run until over a year following the death so that provision of the probate code was without effect.”
Augustson v. Graham, 895 P.2d 20 (Wash. Ct. App. 1995). · cites it 15× “Augustson contends, inter alia, that the trial court erred in failing to recognize that the action was timely pursuant to RCW 4.16.200 and the probate nonclaim statute, RCW 11.”
Nelson v. Schnautz, 141 Wash. App. 466 (Wash. Ct. App. 2007). “According to RCW 4.16.200, actions against a decedent are governed by the probate statutes, chapter 11.”
Schwartz v. Douglas, 991 P.2d 665 (Wash. Ct. App. 2000). “RCW 4.16.200. Former RCW 11.40.011 provides a special limitation on claims against insurers: 2 The time limitations under this chapter for serving and fil *839 ing of claims shall not accrue to the benefit of any liability or casualty insurer as to claims against the deceased…”
Nelson v. Schnautz, 170 P.3d 69 (Wash. Ct. App. 2007). “According to RCW 4.16.200, actions against a decedent are governed by the probate statutes, chapter 11.”
In re the Est. of Henington, 331 P.3d 112 (Wash. Ct. App. 2014). · cites it 2× “” A creditor must then follow the claims procedures established in chapter 11.40 RCW or be forever barred from making a claim or commencing an action against the decedent.”
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