Revised Code of Washington

Wash. Rev. Code § 4.28.080 (2026)

Summons, how served

✓ current as of May 2026

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Service made in the modes provided in this section is personal service. The summons shall be served by delivering a copy thereof, as follows:

(1) If the action is against any county in this state, to the county auditor or, during normal office hours, to the deputy auditor, or in the case of a charter county, summons may be served upon the agent, if any, designated by the legislative authority.

(2) If against any town or incorporated city in the state, to the mayor, city manager, or, during normal office hours, to the mayor's or city manager's designated agent or the city clerk thereof.

(3) If against a school or fire district, to the superintendent or commissioner thereof or by leaving the same in his or her office with an assistant superintendent, deputy commissioner, or business manager during normal business hours.

(4) If against a railroad corporation, to any station, freight, ticket or other agent thereof within this state.

(5) If against a corporation owning or operating sleeping cars, or hotel cars, to any person having charge of any of its cars or any agent found within the state.

(6) If against a domestic insurance company, to any agent authorized by such company to solicit insurance within this state.

(7)(a) If against an authorized foreign or alien insurance company, as provided in RCW 48.05.200.

(b) If against an unauthorized insurer, as provided in RCW 48.05.215 and 48.15.150.

(d) If against a nonresident surplus line broker, as provided in RCW 48.15.073.

(e) If against a nonresident insurance producer or title insurance agent, as provided in RCW 48.17.173.

(f) If against a nonresident adjuster, as provided in RCW 48.17.380.

(g) If against a fraternal benefit society, as provided in RCW 48.36A.350.

(h) If against a nonresident reinsurance intermediary, as provided in RCW 48.94.010.

(i) If against a nonresident life settlement provider, as provided in RCW 48.102.011.

(j) If against a nonresident life settlement broker, as provided in RCW 48.102.021.

(k) If against a service contract provider, as provided in RCW 48.110.030.

(l) If against a protection product guarantee provider, as provided in RCW 48.110.055.

(m) If against a discount plan organization, as provided in RCW 48.155.020.

(8) If against a represented entity as defined in RCW 23.95.400, service of process, notice, or demand required or permitted by law to be served on the entity may be made in accordance with RCW 23.95.450.

(9) If against a minor under the age of fourteen years, to such minor personally, and also to his or her father, mother, guardian, or if there be none within this state, then to any person having the care or control of such minor, or with whom he or she resides, or in whose service he or she is employed, if such there be.

(10) If against any person for whom a guardian has been appointed for any cause, then to such guardian.

(11) If against a foreign or alien steamship company or steamship charterer, to any agent authorized by such company or charterer to solicit cargo or passengers for transportation to or from ports in the state of Washington.

(12) If against a self-insurance program regulated by chapter 48.62 RCW, as provided in chapter 48.62 RCW.

(13) If against a party to a real estate purchase and sale agreement under RCW 64.04.220, by mailing a copy by first-class mail, postage prepaid, to the party to be served at his or her usual mailing address or the address identified for that party in the real estate purchase and sale agreement.

(14) In all other cases, to the defendant personally, or by leaving a copy of the summons at the house of his or her usual abode with some person of suitable age and discretion then resident therein.

(15) In lieu of service under subsection (14) of this section, where the person cannot with reasonable diligence be served as described, the summons may be served as provided in this subsection, and shall be deemed complete on the tenth day after the required mailing: By leaving a copy at his or her usual mailing address with a person of suitable age and discretion who is a resident, proprietor, or agent thereof, and by thereafter mailing a copy by first-class mail, postage prepaid, to the person to be served at his or her usual mailing address. For the purposes of this subsection, "usual mailing address" does not include a United States postal service post office box or the person's place of employment.

[ 2025 c 40 s 1; 2015 c 51 s 2; 2012 c 211 s 1; 2011 c 47 s 1; 1997 c 380 s 1; 1996 c 223 s 1; 1991 sp.s. c 30 s 28; 1987 c 361 s 1; 1977 ex.s. c 120 s 1; 1967 c 11 s 1; 1957 c 202 s 1; 1893 c 127 s 7; RRS s 226, part. FORMER PART OF SECTION: 1897 c 97 s 1 now codified in RCW 4.28.081.]

Notes:

Rules of court: Service of process—CR 4(d), (e).

Effective date, implementation, application—1991 sp.s. c 30: See RCW 48.62.900.

Severability—1977 ex.s. c 120: "If any provision of this 1977 amendatory act, or its application to any person or circumstance is held invalid, the remainder of the act, or the application of the provision to other persons or circumstances is not affected." [ 1977 ex.s. c 120 s 3.]

Service of process on

foreign corporation: RCW 23B.15.100.

foreign savings and loan association: RCW 33.32.050.

nonadmitted foreign corporation: RCW 23B.18.040.

nonresident motor vehicle operator: RCW 46.64.040.

Notes of Decisions

Cited in 325 cases (114 in the last 5 years), 1953–2026 · leading case: Sheldon v. Fettig, 919 P.2d 1209 (Wash. 1996).

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Sheldon v. Fettig, 919 P.2d 1209 (Wash. 1996). · cites it 25× “The Wichert court, however, did not decide the question of whether a strict or liberal construction of RCW 4.28.080 was invariably required, stating: "Arguably the rule of liberal construction applies to the present statute, RCW 4.”

Sheldon v. Fettig, 129 Wash. 2d 601 (Wash. 1996). · cites it 21× “The Wichert court, however, did not decide the question of whether a strict or liberal construction of RCW 4.28.080 was invariably required, stating: "Arguably the rule of liberal construction applies to the present statute, RCW 4.”

Witt v. Port of Olympia, 126 Wash. App. 752 (Wash. Ct. App. 2005). · cites it 14× “¶3 To commence review under LUPA, Witt had to deliver “a copy of the petition to the persons identified by or pursuant to RCW 4.28.080 to receive service of process.”

Witt v. Port of Olympia, 109 P.3d 489 (Wash. Ct. App. 2005). · cites it 14× “¶ 3 To commence review under LUPA, Witt had to deliver "a copy of the petition to the persons identified by or pursuant to RCW 4.28.080 to receive service of process.”

Wright v. B & L Props., Inc., 53 P.3d 1041 (Wash. Ct. App. 2002). · cites it 23× “RCW 4.28.080. I. Statutory Requirements Brokaw contends that service on his private mailbox was not authorized by statute.”

Wright v. B&L Props., Inc., 113 Wash. App. 450 (Wash. Ct. App. 2002). · cites it 23× “RCW 4.28.080. I. Statutory Requirements Brokaw contends that service on his private mailbox was not authorized by statute.”

Ohio Sec. Ins. Co. v. AXIS Ins. Co., 413 P.3d 1028 (Wash. 2018). · cites it 16× “The plain language of RCW 4.28.080 and RCW 48.05.200(1) designate the Insurance Commissioner as the exclusive agent to receive service ¶ 7 RCW 4.”

Salts v. Estes, 133 Wash. 2d 160 (Wash. 1997). · cites it 25× “DISCUSSION RCW 4.28.080 describes at length how a summons may be served on a defendant.”

Lybbert v. Grant Cnty., 1 P.3d 1124 (Wash. 2000). · cites it 7× “RCW 4.28.080 states in pertinent part: “Service made in the modes provided in this section shall be taken and held to be personal service.”

Salts v. Estes, 943 P.2d 275 (Wash. 1997). · cites it 25× “DISCUSSION RCW 4.28.080 describes at length how a summons may be served on a defendant.”

Scanlan v. Townsend, 336 P.3d 1155 (Wash. 2014). · cites it 9× “We granted review of Townsend’s claim that Scanlan failed to comply with RCW 4.28.080(15), which requires serving a copy of the summons “to the defendant personally, or by leaving a copy of the summons at the house of his or her usual abode with some person of suitable age and…”

O'NEILL v. Farmers Ins. Co. of Washington, 125 P.3d 134 (Wash. Ct. App. 2004). · cites it 11× “2d 296 (1986), "[t]he subsections of RCW 4.28.080 seem clear and explicit in their requirements on how to effectuate service.”

Show all 325 citing cases →

— Wash. Rev. Code § 4.28.080(1) — 24 cases

Lybbert v. Grant Cnty., 1 P.3d 1124 (Wash. 2000). “RCW 4.28.080 states in pertinent part: “Service made in the modes provided in this section shall be taken and held to be personal service.”

Davidheiser v. Pierce Cnty., 960 P.2d 998 (Wash. Ct. App. 1998).

Diehl v. W. Washington Growth Mgmt. Hearings Bd., 153 Wash. 2d 207 (Wash. 2004).

Diehl v. W. Wash. Growth Mgmt. Hearings Bd., 103 P.3d 193 (Wash. 2004).

Nitardy v. Snohomish Cnty., 712 P.2d 296 (Wash. 1986).

— Wash. Rev. Code § 4.28.080(10) — 44 cases

Reiner v. Pittsburg Des Moines Corp., 680 P.2d 55 (Wash. 1984).

Seahavn, Ltd. v. Glitnir Bank, 226 P.3d 141 (Wash. Ct. App. 2010).

Ohio Sec. Ins. Co. v. AXIS Ins. Co., 413 P.3d 1028 (Wash. 2018). “The plain language of RCW 4.28.080 and RCW 48.05.200(1) designate the Insurance Commissioner as the exclusive agent to receive service ¶ 7 RCW 4.”

SeaHAVN, Ltd. v. Bank, 154 Wash. App. 550 (Wash. Ct. App. 2010).

Hein v. Taco Bell, Inc., 803 P.2d 329 (Wash. Ct. App. 1991).

— Wash. Rev. Code § 4.28.080(11) — 1 case

Hayward v. Hansen, 628 P.2d 1326 (Wash. Ct. App. 1981).

— Wash. Rev. Code § 4.28.080(12) — 3 cases

Scott v. Goldman, 917 P.2d 131 (Wash. Ct. App. 1996).

In the Matter of the Vulnerable Adult Petition for: Marion Cox (Wash. Ct. App. 2024).

— Wash. Rev. Code § 4.28.080(13) — 1 case

Head v. Kommandit-Gesellschaft MS San Alvaro Offen Reederei GmbH & Co., 17 F. Supp. 3d 1099 (W.D. Wash. 2014).

— Wash. Rev. Code § 4.28.080(14) — 18 cases

Haberman v. Washington Pub. Power Supply Sys., 750 P.2d 254 (Wash. 1988).

Wichert v. Cardwell, 812 P.2d 858 (Wash. 1991).

French v. Gabriel, 788 P.2d 569 (Wash. Ct. App. 1990).

Reiner v. Pittsburg Des Moines Corp., 680 P.2d 55 (Wash. 1984).

Thayer v. Edmonds, 503 P.2d 1110 (Wash. Ct. App. 1972).

— Wash. Rev. Code § 4.28.080(15) — 78 cases

Sheldon v. Fettig, 919 P.2d 1209 (Wash. 1996). “The Wichert court, however, did not decide the question of whether a strict or liberal construction of RCW 4.28.080 was invariably required, stating: "Arguably the rule of liberal construction applies to the present statute, RCW 4.”

Sheldon v. Fettig, 129 Wash. 2d 601 (Wash. 1996). “The Wichert court, however, did not decide the question of whether a strict or liberal construction of RCW 4.28.080 was invariably required, stating: "Arguably the rule of liberal construction applies to the present statute, RCW 4.”

Salts v. Estes, 133 Wash. 2d 160 (Wash. 1997). “DISCUSSION RCW 4.28.080 describes at length how a summons may be served on a defendant.”

Scanlan v. Townsend, 336 P.3d 1155 (Wash. 2014). “We granted review of Townsend’s claim that Scanlan failed to comply with RCW 4.28.080(15), which requires serving a copy of the summons “to the defendant personally, or by leaving a copy of the summons at the house of his or her usual abode with some person of suitable age and…”

Salts v. Estes, 943 P.2d 275 (Wash. 1997). “DISCUSSION RCW 4.28.080 describes at length how a summons may be served on a defendant.”

— Wash. Rev. Code § 4.28.080(15)(1997) — 2 cases

Viet Tuan Nguyen v. Asset Acceptance, Llc. (Wash. Ct. App. 2017).

Mark Hopkins, Et Ux, Resp/cross-app v. Kirk & Jennifer Banks As Assignees For Skyles, App/cross-resp (Wash. Ct. App. 2017).

— Wash. Rev. Code § 4.28.080(16) — 52 cases

Wright v. B & L Props., Inc., 53 P.3d 1041 (Wash. Ct. App. 2002). “RCW 4.28.080. I. Statutory Requirements Brokaw contends that service on his private mailbox was not authorized by statute.”

Wright v. B&L Props., Inc., 113 Wash. App. 450 (Wash. Ct. App. 2002). “RCW 4.28.080. I. Statutory Requirements Brokaw contends that service on his private mailbox was not authorized by statute.”

Goettemoeller v. Twist, 253 P.3d 405 (Wash. Ct. App. 2011).

Blankenship v. Kaldor, 57 P.3d 295 (Wash. Ct. App. 2002).

Luz Castellon, et vir v. Sergio Rodriguez, et ux, 418 P.3d 804 (Wash. Ct. App. 2018).

— Wash. Rev. Code § 4.28.080(17) — 15 cases

Lafawnda Williams v. Matthew Mccandlis (Wash. Ct. App. 2020).

Frerks v. Wolf (W.D. Wash. 2020).

Lauriane Narin v. Mohamed S. Abubakar (Wash. Ct. App. 2019).

Summit Homeowners Ass'n, Resp v. Glenn R. Oakes & Cindy R. Oakes, App (Wash. Ct. App. 2017).

Heidi Diep v. Myurie J. Ausler (Wash. Ct. App. 2019).

— Wash. Rev. Code § 4.28.080(2) — 26 cases

Meadowdale Neighborhood Comm. v. City of Edmonds, 616 P.2d 1257 (Wash. Ct. App. 1980).

Kitsap Cnty. Fire Prot. Dist. No. 7 v. Kitsap Cnty. Boundary Review Bd., 943 P.2d 380 (Wash. Ct. App. 1997).

Bunko v. City of Puyallup Civil Serv. Comm'n, 975 P.2d 1055 (Wash. Ct. App. 1999).

Jeff Young, V. City Of Port Angeles (Wash. Ct. App. 2024).

Brandon Welch v. City Of Burlington (Wash. Ct. App. 2018).

— Wash. Rev. Code § 4.28.080(3) — 1 case

Sundberg v. Shelton Sch. Dist. No 309 (W.D. Wash. 2024).

— Wash. Rev. Code § 4.28.080(4) — 4 cases

Morris v. Palouse River & Coulee City Rr, 203 P.3d 1069 (Wash. Ct. App. 2009).

Morris v. Palouse River & Coulee City R.R., 149 Wash. App. 366 (Wash. Ct. App. 2009).

Lockhart v. Burlington N. R.R., 750 P.2d 1299 (Wash. Ct. App. 1988).

Kay B. Kayongo v. Westfield, Llc. (Wash. Ct. App. 2015).

— Wash. Rev. Code § 4.28.080(5) — 2 cases

Morris v. Palouse River & Coulee City Rr, 203 P.3d 1069 (Wash. Ct. App. 2009).

Morris v. Palouse River & Coulee City R.R., 149 Wash. App. 366 (Wash. Ct. App. 2009).

— Wash. Rev. Code § 4.28.080(6) — 3 cases

O'NEILL v. Farmers Ins. Co. of Washington, 125 P.3d 134 (Wash. Ct. App. 2004). “2d 296 (1986), "[t]he subsections of RCW 4.28.080 seem clear and explicit in their requirements on how to effectuate service.”

O'Neill v. Farmers Ins., 125 P.3d 134 (Wash. Ct. App. 2004).

Chandrruangphen v. City Of Sammamish (Wash. 2026).

— Wash. Rev. Code § 4.28.080(7) — 3 cases

Powell v. Sphere Drake Ins. P.L.C., 988 P.2d 12 (Wash. Ct. App. 1999).

Powell v. Sphere Drake Ins. PLC, 988 P.2d 12 (Wash. Ct. App. 1999).

Kiblen v. Mut. of Omaha Ins., 708 P.2d 1215 (Wash. Ct. App. 1985).

— Wash. Rev. Code § 4.28.080(7)(a) — 4 cases

Thomas Anderson v. State Farm Mut. Auto. Ins., 917 F.3d 1126 (9th Cir. 2019).

Johnson v. QBE Ins. Corp. (W.D. Wash. 2024).

Reger v. Century Nat'l Ins. Co. (W.D. Wash. 2022).

— Wash. Rev. Code § 4.28.080(8) — 3 cases

Keller v. Mountlake Terrace Code Enf't (W.D. Wash. 2025).

Stephens (E.D. Wash. 2025).

Breann Acord & Keith Acord v. Squeaky's Lube Express, Inc. (Wash. Ct. App. 2026).

— Wash. Rev. Code § 4.28.080(9) — 54 cases

Witt v. Port of Olympia, 126 Wash. App. 752 (Wash. Ct. App. 2005). “¶3 To commence review under LUPA, Witt had to deliver “a copy of the petition to the persons identified by or pursuant to RCW 4.28.080 to receive service of process.”

Witt v. Port of Olympia, 109 P.3d 489 (Wash. Ct. App. 2005). “¶ 3 To commence review under LUPA, Witt had to deliver "a copy of the petition to the persons identified by or pursuant to RCW 4.28.080 to receive service of process.”

Spencer v. Franklin Hills Health-Spokane, LLC, 548 P.3d 193 (Wash. 2024).

Quality Rock Prods., Inc. v. Thurston Cnty., 108 P.3d 805 (Wash. Ct. App. 2005).

Quality Rock Prods., Inc. v. Thurston Cnty., 126 Wash. App. 250 (Wash. Ct. App. 2005).

— Wash. Rev. Code § 4.28.080(H) — 1 case

Hayward v. Hansen, 628 P.2d 1326 (Wash. Ct. App. 1981).

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