Wash. Rev. Code » Title 4 · Chapter 4.24
Revised Code of Washington

Wash. Rev. Code § 4.24.595 (2026)

✓ current as of May 2026
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(1) Governmental entities, and their officers, agents, employees, and volunteers, are not liable in tort for any of their acts or omissions in emergent placement investigations of child abuse or neglect under chapter 26.44 RCW including, but not limited to, any determination to leave a child with a parent, custodian, or guardian, or to return a child to a parent, custodian, or guardian, unless the act or omission constitutes gross negligence. Emergent placement investigations are those conducted prior to a shelter care hearing under RCW 13.34.065.
(2) The department of children, youth, and families and its employees shall comply with the orders of the court, including shelter care and other dependency orders, and are not liable for acts performed to comply with such court orders. In providing reports and recommendations to the court, employees of the department of children, youth, and families are entitled to the same witness immunity as would be provided to any other witness.
[ 2017 3rd sp.s. c 6 s 301; 2012 c 259 s 13.]

Notes:

Effective date—2017 3rd sp.s. c 6 ss 102, 104-115, 201-227, 301-337, 401-419, 501-513, 801-803, and 805-822: See note following RCW 43.216.025.
Conflict with federal requirements—2017 3rd sp.s. c 6: See RCW 43.216.908.
Notes of Decisions
Cited in 14 cases (10 in the last 5 years), 2019–2026 · leading case: State Of Washington, V Michelle A. Desmet, 485 P.3d 356 (Wash. Ct. App. 2021).
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State Of Washington, V Michelle A. Desmet, 485 P.3d 356 (Wash. Ct. App. 2021). · cites it 49× “595(1) provides that absent gross negligence, governmental entities and their employees are “not liable in tort for any of their acts or omissions in emergent placement investigations of child abuse or neglect under chapter 26.”
Chen v. D'Amico (W.D. Wash. 2020). · cites it 33× “) At the conference, State Defendants’ counsel informed the court that they 17 intended to file a motion for reconsideration of the court’s ruling on Plaintiffs’ negligent 18 investigation claim on the ground that RCW 4.24.595 requires the court to apply a gross 19 negligence…”
Ian Atkerson v. Dep't of Child., Youth & Families (Wash. Ct. App. 2024). · cites it 22× “” A review of both RCW 4.24.595 subsections shows that the legislature created a temporal divide between when tort liability would be premised on a gross negligence standard, RCW 4.”
Atkerson v. Dep't of Child., Youth, & Fams. (Wash. 2025). · cites it 20× “SCOPE OF RCW 4.24.595 Whether section .595 applies throughout a child abuse investigation is a question of statutory interpretation we review de novo.”
W.m. & Erin Olson, V. State Of Washington, 498 P.3d 48 (Wash. Ct. App. 2021). “Questions of fact exist regarding negligence – and gross negligence if RCW 4.24.595(1) applies – and proximate cause.”
Medicraft v. State of Washington (W.D. Wash. 2023). · cites it 9× “11 RCW 4.24.595 grants DCYF and its employees limited immunity (1) from negligence in 12 emergent placement investigations (prior to a shelter care hearing), except when DCYF engages in 13 gross negligence and (2) from harm proximately caused by “acts performed to comply with .”
Thomas Stout, Appellant/cross-respondent V. Dcyf, Respondents/cross-appellants (Wash. Ct. App. 2026). · cites it 6× “” RCW 4.24.595(1); Atkerson, 4 Wn.3d at 315-16.”
L.g., V. Wa State Dcyf, Et Ano (Wash. Ct. App. 2026). · cites it 6× “3d at 316 (“RCW 4.24.595 does not apply only to acts or omissions that result in shelter care hearings.”
Chen v. D'Amico (W.D. Wash. 2020). · cites it 4× “) Defendants rely on RCW 4.24.595(1), which states: 10 Governmental entities, and their officers, agents, employees, and volunteers, are not liable in tort for any of their acts or omissions in emergent placement 11 investigations of child abuse or neglect under chapter 26.”
Cheesman v. DSHS Region 1/DCFS Childrens Admin. (E.D. Wash. 2019). · cites it 2× “See 23 Wash. Rev. Code § 4.24.595 . Plaintiffs have not alleged Defendants committed 24 gross negligence.”
Chiat v. State of Washington (W.D. Wash. 2020). · cites it 2× “DSHS and its employees cannot be held liable 19 for complying with orders of the Juvenile Court, including shelter care and other 20 dependency orders, pursuant to RCW 4.24.595(2). Thus, DSHS is statutorily immune 21 from liability for tortious interference with the parent/child…”
Hartman v. State of Washington Dep't of Child. Youth & Families (W.D. Wash. 2025). · cites it 2× “Counts V, VII, And VIII – Statutory Tort Immunity for Negligent Investigation of Medical Child Abuse, IIED, and NIED 2 RCW 4.24.595 provides a limited grant of immunity to governmental entities and, 3 in pertinent part, their officers, agents, and employees from tort liability…”
Show all 14 citing cases →
— Wash. Rev. Code § 4.24.595(1) — 10 cases
State Of Washington, V Michelle A. Desmet, 485 P.3d 356 (Wash. Ct. App. 2021). “595(1) provides that absent gross negligence, governmental entities and their employees are “not liable in tort for any of their acts or omissions in emergent placement investigations of child abuse or neglect under chapter 26.”
Ian Atkerson v. Dep't of Child., Youth & Families (Wash. Ct. App. 2024). “” A review of both RCW 4.24.595 subsections shows that the legislature created a temporal divide between when tort liability would be premised on a gross negligence standard, RCW 4.”
W.m. & Erin Olson, V. State Of Washington, 498 P.3d 48 (Wash. Ct. App. 2021). “Questions of fact exist regarding negligence – and gross negligence if RCW 4.24.595(1) applies – and proximate cause.”
Atkerson v. Dep't of Child., Youth, & Fams. (Wash. 2025). “SCOPE OF RCW 4.24.595 Whether section .595 applies throughout a child abuse investigation is a question of statutory interpretation we review de novo.”
Chen v. D'Amico (W.D. Wash. 2020). “) At the conference, State Defendants’ counsel informed the court that they 17 intended to file a motion for reconsideration of the court’s ruling on Plaintiffs’ negligent 18 investigation claim on the ground that RCW 4.24.595 requires the court to apply a gross 19 negligence…”
— Wash. Rev. Code § 4.24.595(2) — 8 cases
State Of Washington, V Michelle A. Desmet, 485 P.3d 356 (Wash. Ct. App. 2021). “595(1) provides that absent gross negligence, governmental entities and their employees are “not liable in tort for any of their acts or omissions in emergent placement investigations of child abuse or neglect under chapter 26.”
Medicraft v. State of Washington (W.D. Wash. 2023). “11 RCW 4.24.595 grants DCYF and its employees limited immunity (1) from negligence in 12 emergent placement investigations (prior to a shelter care hearing), except when DCYF engages in 13 gross negligence and (2) from harm proximately caused by “acts performed to comply with .”
Chen v. D'Amico (W.D. Wash. 2020). “) At the conference, State Defendants’ counsel informed the court that they 17 intended to file a motion for reconsideration of the court’s ruling on Plaintiffs’ negligent 18 investigation claim on the ground that RCW 4.24.595 requires the court to apply a gross 19 negligence…”
Ian Atkerson v. Dep't of Child., Youth & Families (Wash. Ct. App. 2024). “” A review of both RCW 4.24.595 subsections shows that the legislature created a temporal divide between when tort liability would be premised on a gross negligence standard, RCW 4.”
Chiat v. State of Washington (W.D. Wash. 2020). “DSHS and its employees cannot be held liable 19 for complying with orders of the Juvenile Court, including shelter care and other 20 dependency orders, pursuant to RCW 4.24.595(2). Thus, DSHS is statutorily immune 21 from liability for tortious interference with the parent/child…”
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