Revised Code of Washington

Wash. Rev. Code § 4.20.020 (2026)

✓ current as of May 2026
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Every action under RCW 4.20.010 shall be for the benefit of the spouse, state registered domestic partner, child or children, including stepchildren, of the person whose death shall have been so caused. If there is no spouse, state registered domestic partner, or such child or children, such action may be maintained for the benefit of the parents or siblings of the deceased.
In every such action the trier of fact may give such damages as, under all circumstances of the case, may to them seem just.
[ 2019 c 159 s 2; 2011 c 336 s 90; 2007 c 156 s 29; 1985 c 139 s 1; 1973 1st ex.s. c 154 s 2; 1917 c 123 s 2; RRS s 183-1.]

Notes:

Retroactive application2019 c 159: See note following RCW 4.20.010.
Severability1973 1st ex.s. c 154: See note following RCW 2.12.030.
Notes of Decisions
Cited in 121 cases (10 in the last 5 years), 1953–2025 · leading case: Kellogg v. Nat'l R.R. Passenger Corp., 504 P.3d 796 (Wash. 2022).
Kellogg v. Nat'l R.R. Passenger Corp., 504 P.3d 796 (Wash. 2022). · cites it 22× “Former RCW 4.20.020 (2011). The wrongful death beneficiary statute in effect at that time also denied any recovery to beneficiaries like parents or siblings if they did not reside in the United States.”
Tait v. Wahl, 987 P.2d 127 (Wash. Ct. App. 1999). · cites it 16× “Tait contends that the list of beneficiaries enumerated in RCW 4.20.020 should be liberally construed to include her "parent-child like" relationship with the decedent and her children's "familial" relationship with the decedent: "If it is the intent of this legislation and/or…”
Masunaga v. Gapasin, 790 P.2d 171 (Wash. Ct. App. 1990). · cites it 15× “) An analogous provision in the general wrongful death statute, RCW 4.20.020, provides that parents and siblings may benefit from a wrongful death action brought by the deceased's personal representative if the parents or siblings are "dependent upon the deceased person for…”
In Re the Est. of Blessing, 273 P.3d 975 (Wash. 2012). · cites it 14× “¶1 This case involves whether the children of the decedent’s predeceased spouse can be considered “stepchildren” under the wrongful death recovery statute, RCW 4.20.020. The decedent, Audrey Blessing, and the children’s father were married in 1964.”
Triplett v. Dep't of Soc. & Health Servs., 166 Wash. App. 423 (Wash. Ct. App. 2012). · cites it 17× “Respondents sued DSHS under RCW 4.20.020, RCW 4.20.046, and/or RCW 4.”
Philippides v. Bernard, 88 P.3d 939 (Wash. 2004). · cites it 5× “010, and also under the wrongful death and survival statutes, RCW 4.20.020 and RCW 4.20.060. Defendants moved to dismiss the claims.”
Armantrout v. Carlson, 214 P.3d 914 (Wash. 2009). · cites it 13× “We are asked to decide if the provision of services that have an economic value may be considered by the trier of fact when determining whether a parent was "dependent for support" on an adult child as required by RCW 4.20.020 to maintain an action for wrongful death.”
Armantrout v. Carlson, 166 Wash. 2d 931 (Wash. 2009). · cites it 13× “We are asked to decide if the provision of services that have an economic value may be considered by the trier of fact when determining whether a parent was “dependent for support” on an adult child as required by RCW 4.20.020 to maintain an action for wrongful death.”
Armijo v. Wesselius, 440 P.2d 471 (Wash. 1968). · cites it 16× “Resolution of the question is dependent upon the meaning to be attributed to the words "child or children" as they appear in RCW 4.20.020. Tomas Telles died on October 20, 1965, as a result of a collision near Wapato, Washington, between his automobile and a tractor driven by…”
Klossner v. San Juan Cnty., 605 P.2d 330 (Wash. 1980). · cites it 12× “Petitioner San Juan County appeals from a decision of the Court of Appeals which reversed the trial court's order granting summary judgment and dismissing respondent Patricia Klossner's action brought under the wrongful death and survival statutes, RCW 4.20.020 and RCW 4.20.060.…”
Philippides v. Bernard, 151 Wash. 2d 376 (Wash. 2004). · cites it 4× “010, and also under the wrongful death and survival statutes, RCW 4.20.020 and RCW 4.20.060. Defendants moved to dismiss the claims.”
Beggs v. Dep't of Soc. & Health Servs., 171 Wash. 2d 69 (Wash. 2011). · cites it 5× “11 RCW 4.20.020 provides: Every such action shall be for the benefit of the wife, husband, state registered domestic partner, child or children, including stepchildren, of the person whose death shall have been so caused [under RCW 4.”
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