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

Wash. Rev. Code § 4.16.280 (2026)

New promise must be in writing

✓ current as of May 2026
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No acknowledgment or promise shall be sufficient evidence of a new or continuing contract whereby to take the case out of the operation of this chapter, unless it is contained in some writing signed by the party to be charged thereby; except, an acknowledgment or promise made after the limitation period has expired shall not restart, revive, or extend the limitation period. This section shall not alter the effect of any payment of principal or interest.
[ 2019 c 377 s 2; Code 1881 s 44; 1877 p 10 s 45; 1854 p 365 s 18; RRS s 176.]
Notes of Decisions
Cited in 23 cases (8 in the last 5 years), 1977–2025 · leading case: Tragopan Props., LLC v. Smith Dev., Inc., 263 P.3d 613 (Wash. Ct. App. 2011).
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Tragopan Props., LLC v. Smith Dev., Inc., 263 P.3d 613 (Wash. Ct. App. 2011). · cites it 12× “1 But such an action may be maintained under RCW 4.16.280 by a written acknowledgment or promise signed by the debtor that recognizes the debt’s existence, is communicated to the creditor, and does not indicate an intent not to pay.”
Lombardo v. Mottola, 566 P.2d 1273 (Wash. Ct. App. 1977). · cites it 6× “RCW 4.16.280. A review of the statute shows two distinct methods for revival of the remedy: (1) an acknowledgment in writing that the debt is unpaid, or (2) a promise to pay the debt.”
Fetty v. Wenger, 36 P.3d 1123 (Wash. Ct. App. 2002). · cites it 3× “RCW 4.16.280 sets forth the conditions under which the statute of limitations may be restarted: No acknowledgment or promise shall be sufficient evidence of a new or continuing contract whereby to take the case out of the operation of this chapter, unless it is contained in some…”
Fetty v. Wenger, 110 Wash. App. 598 (Wash. Ct. App. 2001). · cites it 3× “RCW 4.16.280 sets forth the conditions under which the statute of limitations may be restarted: No acknowledgment or promise shall be sufficient evidence of a new or continuing contract whereby to take the case out of the operation of this chapter, unless it is contained in some…”
Matson v. Weidenkopf, 3 P.3d 805 (Wash. Ct. App. 2000). · cites it 2× “His argument raises two possible issues: Are the letters to the Matsons sufficient to create an acknowledgment of the debt and, if so, did Vance Shafer's acknowledgment bind his exwife, Julie Shafer? [1] The second issue is dispositive.”
Matson v. Weidenkopf, 101 Wash. App. 472 (Wash. Ct. App. 2000). · cites it 2× “His argument raises two possible issues: Are the letters to the Matsons sufficient to create an acknowledgment of the debt and, if so, did Vance Shafer’s acknowledgment bind his ex-wife, Julie Shafer? 1 The second issue is dispositive. Assuming that the letters are sufficient to…”
Jewell v. Long, 876 P.2d 473 (Wash. Ct. App. 1994). · cites it 2× “It agreed with Raymond Jewell that David Jewell had acknowledged the 1982 debt when he gave the 1985 deed of trust, and that the statute of limitations had restarted as a result.”
Copper Creek (Marysville) Homeowners Ass'n v. Kurtz, 532 P.3d 601 (Wash. 2023). “4 Thus, Copper Creek recognized that the Kurtzes’ alleged request for a short sale might be dispositive of Copper Creek’s statute of limitations argument.”
Rea v. Rea, 576 P.2d 84 (Wash. Ct. App. 1978). “RCW 4.16.280 provides: No acknowledgement or promise shall be sufficient evidence of a new or continuing contract whereby to take the case out of the operation of this chapter, unless it is contained in some writing signed by the party to be charged thereby; but this section…”
Campbell v. Loftus, 36 Wash. App. 678 (Wash. Ct. App. 1984). · cites it 3× “The Campbells correctly point out the law provides an exception to the 6-year statute of limitation, RCW 4.16.280. 2 However, this statute provides for revival of the remedy for recovery on a debt.”
Garlock v. OptimisCorp (W.D. Wash. 2023). · cites it 8× “However, the 18 limitations period may be renewed pursuant to RCW 4.16.280 if the debtor issues a written 19 acknowledgment of the debt.”
Burnham v. Burnham, 567 P.2d 242 (Wash. Ct. App. 1977). “In any event RCW 4.16.280 requires that, in order to take a case out of the operation of the statute of limitations, the acknowledgment or promise must be in writing and must be signed by the party to be charged.”
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