Revised Code of Washington
Wash. Rev. Code § 4.28.150 (2026)
✓ current as of May 2026
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In any action brought to determine any adverse claim, estate, lien, or interest in real property, or to quiet title to real property, the plaintiff may include as a defendant in such action, and insert in the title thereof, in addition to the names of such persons or parties as appear of record to have, and other persons or parties who are known to have, some title, claim, estate, lien, or interest in the lands in controversy, the following, viz.: "Also all other persons or parties unknown claiming any right, title, estate, lien, or interest in the real estate described in the complaint herein." And service of summons may be had upon all such unknown persons or parties defendant by publication as provided by law in case of nonresident defendants.
[ 1903 c 144 s 3; RRS s 231.]
Notes:
Publication of legal notices: Chapter 65.16 RCW.
Notes of Decisions
Cited in 6
cases, 1952–2020 · leading case: Ralph v. Dep't of Nat. Resources, 343 P.3d 342 (Wash. 2014).
Ralph v. Dep't of Nat. Resources, 343 P.3d 342 (Wash. 2014). “Instead, the legislature provides mechanisms outside of RCW 4.12.010 to protect interested persons and to facilitate the efficient transfer and resolution of real property matters.”
Finch v. Matthews, 443 P.2d 833 (Wash. 1968). “RCW 4.28.150. Judgment was entered quieting plaintiffs’ title against the claim of all such possible claimants to the fee in Indianapolis Street, and the plaintiffs’ title to such fee cannot be questioned, and is not now, an issue in this case.”
Valentine v. Portland Timber & Land Holding Co., 547 P.2d 912 (Wash. Ct. App. 1976). “Defendants next argue that the mortgagee should have complied with the provisions of RCW 4.28.150 and 4.28.160, providing for service by publication upon unknown parties claiming an interest in the real estate, need not be considered.”
Symington v. Hudson, 243 P.2d 484 (Wash. 1952). “RCW4.28.150' (Rem. Rev. Stat., § 231) provides: “In any action brought to determine any adverse claim, estate, lien, or interest in real property, or to quiet title to real property, the plaintiff may include as a defendant .”
Ralph v. Dep't of Nat. Res. (Wash. 2014). “One example is RCW 4.28.150. This statute requires plaintiffs to record at the onset of litigation a lis pendens in each county where disputed property is located, on pain of potentially not being able to enforce their judgment.”
Deutsche Bank Nat'l Trust v. Michael & Bonnie Shields (Wash. Ct. App. 2020). “6 While this reality should be kept in mind when 5 Shields contends that because Deutsche Bank included as a defendant “all other persons or parties unknown claiming any right, title, estate, lien, or interest in the real estate described in the complaint herein,” Regional was a…”
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