Revised Code of Washington

Wash. Rev. Code § 4.16.230 (2026)

Statute tolled by judicial proceedings

✓ current as of May 2026
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When the commencement of an action is stayed by injunction or a statutory prohibition, the time of the continuance of the injunction or prohibition shall not be a part of the time limited for the commencement of the action.
[Code 1881 s 40; 1877 p 10 s 41; 1854 p 365 s 14; RRS s 172.]
Notes of Decisions
Cited in 20 cases (2 in the last 5 years), 1960–2023 · leading case: Broad v. Mannesmann Anlagenbau, A.G., 10 P.3d 371 (Wash. 2000).
Broad v. Mannesmann Anlagenbau, A.G., 10 P.3d 371 (Wash. 2000). · cites it 5× “*682 Plaintiffs argue that because process cannot be served in this case except through the designated central authority, commencement of this action should be tolled under RCW 4.16.230. That statute provides in relevant part that “[w]hen the commencement of an action is stayed…”
U.S. Bank Nat'l Ass'n as Tr. of Holders of Adjustable Rate Mortg. Trust 2007-2 v. Ukpoma, 438 P.3d 141 (Wash. Ct. App. 2019). · cites it 6× “This is impliedly acknowledged by the secondary opinion's reliance on RCW 4.16.230 instead of RCW 61.24.030. ¶21 RCW 4.”
Duke v. Boyd, 942 P.2d 351 (Wash. 1997). · cites it 2× “220 (defendant is in military service); RCW 4.16.230 (action stayed by judicial proceedings).”
Duke v. Boyd, 133 Wash. 2d 80 (Wash. 1997). · cites it 2× “220 (defendant is in military service); RCW 4.16.230 (action stayed by judicial proceedings).”
Petcu v. State, 86 P.3d 1234 (Wash. Ct. App. 2004). · cites it 2× “RCW 4.16.230 specifies when judicial proceedings toll the statute of limitations, providing: "When the commencement of an action is stayed by injunction or a statutory prohibition, the time of the continuance of the injunction or prohibition shall not be a part of the time…”
Broad v. Mannesmann Anlagenbau, AG, 10 P.3d 371 (Wash. 2000). · cites it 5× “Plaintiffs argue that because process cannot be served in this case except through the designated central authority, commencement of this action should be tolled under RCW 4.16.230. That statute provides in relevant part that "[w]hen the commencement of an action is stayed by .”
Seamans v. Walgren, 514 P.2d 166 (Wash. 1973). · cites it 3× “It also held that the statute of limitations was tolled during the period a legislator was immune from civil process by virtue of RCW 4.16.230. 2 Respondent argues that article 2, section 16 does not provide immunity from service of process.”
Castro v. Stanwood Sch. Dist. No. 401, 151 Wash. 2d 221 (Wash. 2004). “RCW 4.16.230. As the general tolling statute explains, a tolling period generally does not take away from the time limited for the commencement of an action.”
Castro v. Stanwood Sch. Dist. No. 401, 86 P.3d 1166 (Wash. 2004). “RCW 4.16.230. As the general tolling statute explains, a tolling period generally does not take away from the time limited for the commencement of an action.”
Petcu v. State, 121 Wash. App. 36 (Wash. Ct. App. 2004). “” RCW 4.16.230. Here, no injunction or statutory prohibition prevented Petcu from filing his claims.”
Elliott v. Peterson, 599 P.2d 1282 (Wash. 1979). · cites it 6× “This view also finds support in RCW 4.16.230, [2] which provides for the tolling of the statute where the commencement of an action is stayed by injunction.”
Williams v. Bank of California, N.A., 639 P.2d 1339 (Wash. 1982). “See RCW 4.16.230 and .240. The new complaint adding affirmative allegations against the PRTA directors/officers failed to comply with CR 15, since Williams did not receive express leave of this or the trial court to so amend her complaint.”
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