Revised Code of Washington
Wash. Rev. Code § 4.16.270 (2026)
Effect of partial payment
✓ current as of May 2026
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When any payment has been or shall be made upon any existing contract prior to its applicable limitation period having expired, whether the contract is a bill of exchange, promissory note, bond, or other evidence of indebtedness, if the payment is made after it is due, the limitation period shall restart from the time the most recent payment was made. Any payment on the contract made after the limitation period has expired shall not restart, revive, or extend the limitation period.
Notes of Decisions
Cited in 14
cases (3 in the last 5 years), 1955–2024 · leading case: Watters v. Doud, 596 P.2d 280 (Wash. 1979).
Watters v. Doud, 596 P.2d 280 (Wash. 1979). “200 should be read together with RCW 4.16.270, the partial payment statute, to allow a garnishor to reach community assets on an antenuptial separate debt when judgment on the debt is obtained within 3 years after the last partial payment but not within 3 years after marriage.”
Hamilton v. Pearce, 547 P.2d 866 (Wash. Ct. App. 1976). “RCW 4.16.270. We will refer to this as the “partial payment statute.”
Autovest v. Agosto, 563 P.3d 811 (N.M. 2024). “at 870 ; see Wash. Rev. Code Ann. § 4.16.270 (1877) & § 4.”
Hopper v. Hemphill, 575 P.2d 746 (Wash. Ct. App. 1978). “RCW 4.16.270; Hamilton v. Pearce, 15 Wn. App.”
Keen v. O'rourke, 290 P.2d 976 (Wash. 1955). “” RCW 4.16.270. (Italics ours.) Upon this issue,.”
Nilson v. Castle Rock Sch. Dist., 945 P.2d 765 (Wash. Ct. App. 1997). “On appeal, [3] the court noted: Here the $10,000 loan by Hopper to Hemphill on June 30, 1969, created a present debt and the 3-year statute of limitations commenced running on the date of the loan.”
Kelly v. Allianz Life Ins. Co. of North Am., 314 P.3d 755 (Wash. Ct. App. 2013). “Kelly also argues that Allianz’s “partial payment” tolled the statute of limitations under RCW 4.16.270, which provides that when partial payment is made on an existing contract, the statute of limitations commences from the time the last payment was made.”
Nilson v. Castle Rock Sch. Dist., 945 P.2d 765 (Wash. Ct. App. 1997). “On appeal, 3 the court noted: Here the $10,000 loan by Hopper to Hemphill on June 30, 1969, created a present debt and the 3-year statute of limitations commenced running on the date of the loan.”
Brown v. Deutsche Bank Nat'l Trust Co. (Bankr. W.D. Wash. 2020). “Plastino, RCW 4.16.270 stated: 1 When any payment of principal or interest has been or shall be made upon any existing 2 contract, whether it be a bill of exchange, promissory note, bond or other evidence of indebtedness, if such payment be made after the same shall have become…”
Jess Ortiz v. Inga Sterling (Wash. Ct. App. 2017). “1 Nonetheless, a "partial payment" statute, RCW 4.16.270, provides that a payment on a loan after it has become due resets the statute of limitations clock: When any payment of principal or interest has been or shall be made upon any existing contract, whether it be a bill of…”
Bus. Fin. Corp., Resp. v. Victoria Knoll, Apps. (Wash. Ct. App. 2016). “See RCW 4.16.270. The burden of proving that a voluntary payment was made rests on the party seeking to extend the statute of limitations.”
Wa Fed., Nat'l Assoc., V, Pac. Coast Constr., Llc. (Wash. Ct. App. 2018). “A trial court abuses its discretion if its 3 The Appellants also argue that the bankruptcy trustees’ payments did not affect the statute of limitations under RCW 4.16.270. They claim that the bankruptcy trustees were not their agents, and that the trustees’ payments were…”
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