Wash. Rev. Code » Title 4 · Chapter 4.22
Revised Code of Washington

Wash. Rev. Code § 4.22.050 (2026)

Enforcement of contribution

✓ current as of May 2026
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(1) If the comparative fault of the parties to a claim for contribution has been established previously by the court in the original action, a party paying more than that party's equitable share of the obligation, upon motion, may recover judgment for contribution.
(2) If the comparative fault of the parties to the claim for contribution has not been established by the court in the original action, contribution may be enforced in a separate action, whether or not a judgment has been rendered against either the person seeking contribution or the person from whom contribution is being sought.
(3) If a judgment has been rendered, the action for contribution must be commenced within one year after the judgment becomes final. If no judgment has been rendered, the person bringing the action for contribution either must have (a) discharged by payment the common liability within the period of the statute of limitations applicable to the claimant's right of action against him or her and commenced the action for contribution within one year after payment, or (b) agreed while the action was pending to discharge the common liability and, within one year after the agreement, have paid the liability and commenced an action for contribution.
[ 2011 c 336 s 92; 1981 c 27 s 13.]
Notes of Decisions
Cited in 20 cases (1 in the last 5 years), 1983–2024 · leading case: Washburn v. Beatt Equip. Co., 840 P.2d 860 (Wash. 1992).
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Washburn v. Beatt Equip. Co., 840 P.2d 860 (Wash. 1992). · cites it 2× “At the common law, contribution was not allowed between joint tortfeasors; however, this rule was increasingly subject to criticism, and in 1981 the right to contribution was established in Washington with the basis for contribution being the comparative fault of the tortfeasors.”
George v. Parke-Davis, 733 P.2d 507 (Wash. 1987). · cites it 2× “Furthermore, since Eli Lilly also manufactured and sold DES tablets, then at least in this case it had an affirmative duty to prevent such distribution, both at the retail and wholesale level.”
Smith v. Jackson, 721 P.2d 508 (Wash. 1986). · cites it 3× “First, RCW 4.22.050(3) 1 by its plain language, allows for contribution actions until 1 year after the date of payment by one tortfeasor.”
Kottler v. State, 963 P.2d 834 (Wash. 1998). “040(1) and RCW 4.22.050(2) make it clear contribution may be pursued in a separate action, whether or not a judgment has been entered.”
Kottler v. State, 136 Wash. 2d 437 (Wash. 1998). “040(1) and RCW 4.22.050(2) make it clear contribution may be pursued in a separate action, whether or not a judgment has been entered.”
Avco Corp. v. Crews, 76 F. Supp. 3d 1161 (W.D. Wash. 2015). · cites it 4× “#8 (citing RCW 4.22.050). 1 AVCO likewise requests that the Court deny defendant’s motion for .”
Magana v. Hyundai Motor Am., 141 Wash. App. 495 (Wash. Ct. App. 2007). “” RCW 4.22.050(2) provides: “If the comparative fault of the parties to the claim for contribution has not been established by the court in the original action, contribution may be enforced in a separate action, whether or not a judgment has been rendered against either the…”
Zamora v. Mobil Oil Corp., 704 P.2d 591 (Wash. 1985). “RCW 4.22.050 Enforcement of contribution.”
Controlled Atmosphere, Inc. v. Branom Instrument Co., 748 P.2d 686 (Wash. Ct. App. 1988). “the appropriate statute of limitation for a breach of warranty action? (2) Assuming the statute of limitation for breach of warranty has not run, is there a material issue of fact on the breach of warranty claim? (3) Is there a material issue of fact on the negligence claim? (4)…”
Pietz v. Indermuehle, 949 P.2d 449 (Wash. Ct. App. 1998). “Given the all-inclusive nature of this clause, we find that the settlement agreement between Berry and Pietz extinguished any common liability arising from dealings between Berry and the remaining members of the Vancouver Group.”
Pietz v. Indermuehle, 949 P.2d 449 (Wash. Ct. App. 1998). “RCW 4.22.050 requires parties seeking contribution to commence their enforcement actions within one year of agreeing to discharge the common liability.”
Robinson v. McReynolds, 762 P.2d 1166 (Wash. Ct. App. 1988). “RCW 4.22.050. In our view, this means that one seeking contribution in the same action in which a *641 claim is asserted against him must do so in a timely manner by pleading and proving his right to contribution before suffering a verdict to be entered against him on the…”
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— Wash. Rev. Code § 4.22.050(2) — 6 cases
Kottler v. State, 963 P.2d 834 (Wash. 1998). “040(1) and RCW 4.22.050(2) make it clear contribution may be pursued in a separate action, whether or not a judgment has been entered.”
Kottler v. State, 136 Wash. 2d 437 (Wash. 1998). “040(1) and RCW 4.22.050(2) make it clear contribution may be pursued in a separate action, whether or not a judgment has been entered.”
Magana v. Hyundai Motor Am., 141 Wash. App. 495 (Wash. Ct. App. 2007). “” RCW 4.22.050(2) provides: “If the comparative fault of the parties to the claim for contribution has not been established by the court in the original action, contribution may be enforced in a separate action, whether or not a judgment has been rendered against either the…”
Avco Corp. v. Crews, 76 F. Supp. 3d 1161 (W.D. Wash. 2015). “#8 (citing RCW 4.22.050). 1 AVCO likewise requests that the Court deny defendant’s motion for .”
Hyundai Motor Am. v. Magana, 170 P.3d 1165 (Wash. Ct. App. 2007).
— Wash. Rev. Code § 4.22.050(3) — 5 cases
Smith v. Jackson, 721 P.2d 508 (Wash. 1986). “First, RCW 4.22.050(3) 1 by its plain language, allows for contribution actions until 1 year after the date of payment by one tortfeasor.”
Avco Corp. v. Crews, 76 F. Supp. 3d 1161 (W.D. Wash. 2015). “#8 (citing RCW 4.22.050). 1 AVCO likewise requests that the Court deny defendant’s motion for .”
Baker v. Winger, 822 P.2d 315 (Wash. Ct. App. 1992).
Gerrard v. Craig, 836 P.2d 837 (Wash. Ct. App. 1992).
Westfield Ins. Co. v. Chapel Elec. Co., L.L.C., 2024 Ohio 2736 (Ohio Ct. App. 2024).
— Wash. Rev. Code § 4.22.050(3)(a) — 1 case
Baker v. Winger, 822 P.2d 315 (Wash. Ct. App. 1992).
— Wash. Rev. Code § 4.22.050(3)(b) — 1 case
Baker v. Winger, 822 P.2d 315 (Wash. Ct. App. 1992).
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