Revised Code of Washington

Wash. Rev. Code § 4.28.185 (2026)

✓ current as of May 2026

Find cases: SyfertCases citing this section WA-LEGapp.leg.wa.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

(1) Any person, whether or not a citizen or resident of this state, who in person or through an agent does any of the acts in this section enumerated, thereby submits said person, and, if an individual, his or her personal representative, to the jurisdiction of the courts of this state as to any cause of action arising from the doing of any of said acts:

(a) The transaction of any business within this state;

(b) The commission of a tortious act within this state;

(d) Contracting to insure any person, property, or risk located within this state at the time of contracting;

(e) The act of sexual intercourse within this state with respect to which a child may have been conceived;

(f) Living in a marital relationship within this state notwithstanding subsequent departure from this state, as to all proceedings authorized by chapter 26.09 RCW, so long as the petitioning party has continued to reside in this state or has continued to be a member of the armed forces stationed in this state.

(2) Service of process upon any person who is subject to the jurisdiction of the courts of this state, as provided in this section, may be made by personally serving the defendant outside this state, as provided in RCW 4.28.180, with the same force and effect as though personally served within this state.

(3) Only causes of action arising from acts enumerated herein may be asserted against a defendant in an action in which jurisdiction over him or her is based upon this section.

(4) Personal service outside the state shall be valid only when an affidavit is made and filed to the effect that service cannot be made within the state.

(5) In the event the defendant is personally served outside the state on causes of action enumerated in this section, and prevails in the action, there may be taxed and allowed to the defendant as part of the costs of defending the action a reasonable amount to be fixed by the court as attorneys' fees.

(6) Nothing herein contained limits or affects the right to serve any process in any other manner now or hereafter provided by law.

[ 2011 c 336 s 100; 1977 c 39 s 1; 1975-'76 2nd ex.s. c 42 s 22; 1959 c 131 s 2.]

Notes:

Rules of court: Cf. CR 4(e), CR 12(a), CR 82(a).

Uniform parentage act: Chapter 26.26A RCW.

Notes of Decisions

Cited in 332 cases (81 in the last 5 years), 1960–2026 · leading case: Scott Fetzer Co. v. Weeks, 786 P.2d 265 (Wash. 1990).

Sort: Relevance Newest Treatment

Scott Fetzer Co. v. Weeks, 786 P.2d 265 (Wash. 1990). · cites it 46× “The principal issue presented for decision is whether the fees awards provision of Washington's long-arm statute, RCW 4.28.185(5), authorizes an award of attorney fees when a foreign defendant prevails on jurisdictional grounds.”

Shute v. Carnival Cruise Lines, 783 P.2d 78 (Wash. 1989). · cites it 9× “A Washington resident, injured on a cruise ship in international waters off the coast of Mexico, brought suit against the cruise operator, a Panamanian corporation with its principal place of business in Florida, under the Washington "long-arm" statute, RCW 4.28.185. The United…”

FutureSelect Portfolio Mgmt., Inc. v. Tremont Grp. Holdings, Inc., 331 P.3d 29 (Wash. 2014). · cites it 5× “However, Oppenheimer may renew its jurisdictional challenge after appropriate discovery has been conducted.”

Seahavn, Ltd. v. Glitnir Bank, 226 P.3d 141 (Wash. Ct. App. 2010). · cites it 12× “SeaHAVN alleged that Washington has personal jurisdiction over Glitnir "pursuant to RCW 4.28.185 arising out of specific business transacted in the State of Washington, an agreement reached with a party in the State of Washington, and breach of such agreement.”

Ralph's Concrete v. Concord Concrete Pumps, 225 P.3d 1035 (Wash. Ct. App. 2010). · cites it 13× “¶ 1 At issue is whether service of process by mail on a foreign corporation pursuant to Superior Court Civil Rule (CR) 4(i)(1)(D) is sufficient to confer personal jurisdiction in Washington courts where personal service under the long arm statute, RCW 4.28.185, was not made.…”

Ralph's Concrete Pumping, Inc. v. Concord Concrete Pumps, Inc., 154 Wash. App. 581 (Wash. Ct. App. 2010). · cites it 13× “¶1 At issue is whether service of process by mail on a foreign corporation pursuant to Superior Court Civil Rule (CR) 4(i)(l)(D) is sufficient to confer personal jurisdiction in Washington courts where personal service under the long-arm statute, RCW 4.28.185, was not made.…”

SeaHAVN, Ltd. v. Bank, 154 Wash. App. 550 (Wash. Ct. App. 2010). · cites it 14× “appeals the trial court’s decision to dismiss its breach of contract lawsuit against an Icelandic bank, Glitnir Bank, for lack of personal jurisdiction under Washington’s long-arm statute, RCW 4.28.185. SeaHAVN contends that based on the execution of a nondisclosure agreement in…”

Kim v. Lakeside Adult Fam. Home, 374 P.3d 121 (Wash. 2016). · cites it 4× “While Kim attempted service under RCW 4.28.185, see CP at 1246-48, Thomas has not yet “prevailed in the action.”

Scott Fetzer Co. v. Weeks, 859 P.2d 1210 (Wash. 1993). · cites it 7× “[AJwards of attorney fees under RCW 4.28.185(5) have become all-or-nothing propositions, with trial court decisions accorded unquestioned deference so long as lip service has been paid to the notions of fair play and substantiál justice.”

Mbm Fisheries v. Bollinger Mach. Shop & Shipyard, 804 P.2d 627 (Wash. Ct. App. 1991). · cites it 11× “4 IV Specific Jurisdiction In the alternative, MBM argues that specific jurisdiction over Bollinger exists under RCW 4.28.185, Washington's long-arm statute.”

In re the Marriage of David-Oytan, 288 P.3d 57 (Wash. Ct. App. 2012). · cites it 15× “Kudret also claims he did not have sufficient contacts with the state to satisfy due process and the court should have declined to exercise personal jurisdiction over him as a matter of equity. *798 1. Long-Arm Statute ¶44 Extending the jurisdiction of Washington courts to…”

Moses v. Miller, 548 P.2d 542 (Wash. 1976). · cites it 12× “*714 In this matter, the issue is whether it was error for the Superior Court for Stevens County to deny permanent custody to the mother of four minor children solely on the ground that the court lacked in personam jurisdiction over the nonresident father of the children. We…”

Show all 332 citing cases →

— Wash. Rev. Code § 4.28.185(1) — 37 cases

FutureSelect Portfolio Mgmt., Inc. v. Tremont Grp. Holdings, Inc., 331 P.3d 29 (Wash. 2014). “However, Oppenheimer may renew its jurisdictional challenge after appropriate discovery has been conducted.”

Moses v. Miller, 548 P.2d 542 (Wash. 1976). “*714 In this matter, the issue is whether it was error for the Superior Court for Stevens County to deny permanent custody to the mother of four minor children solely on the ground that the court lacked in personam jurisdiction over the nonresident father of the children. We…”

Smith v. York Food Mach. Co., 504 P.2d 782 (Wash. 1972).

Mbm Fisheries v. Bollinger Mach. Shop & Shipyard, 804 P.2d 627 (Wash. Ct. App. 1991). “4 IV Specific Jurisdiction In the alternative, MBM argues that specific jurisdiction over Bollinger exists under RCW 4.28.185, Washington's long-arm statute.”

Thiry v. Atl. Monthly Co., 445 P.2d 1012 (Wash. 1968).

— Wash. Rev. Code § 4.28.185(1)(a) — 25 cases

Seahavn, Ltd. v. Glitnir Bank, 226 P.3d 141 (Wash. Ct. App. 2010). “SeaHAVN alleged that Washington has personal jurisdiction over Glitnir "pursuant to RCW 4.28.185 arising out of specific business transacted in the State of Washington, an agreement reached with a party in the State of Washington, and breach of such agreement.”

Shute v. Carnival Cruise Lines, 783 P.2d 78 (Wash. 1989). “A Washington resident, injured on a cruise ship in international waters off the coast of Mexico, brought suit against the cruise operator, a Panamanian corporation with its principal place of business in Florida, under the Washington "long-arm" statute, RCW 4.28.185. The United…”

Raymond v. Robinson, 15 P.3d 697 (Wash. Ct. App. 2001).

Harbison v. Garden Valley Outfitters, Inc., 849 P.2d 669 (Wash. Ct. App. 1993).

— Wash. Rev. Code § 4.28.185(1)(b) — 21 cases

Lewis v. Bours, 835 P.2d 221 (Wash. 1992).

Walker v. Bonney-watson Co., 823 P.2d 518 (Wash. Ct. App. 1992).

Harbison v. Garden Valley Outfitters, Inc., 849 P.2d 669 (Wash. Ct. App. 1993).

— Wash. Rev. Code § 4.28.185(1)(c) — 1 case

Fu-cheng Chen, V. Fukuen Eric Chen & Ming-fen Chen (Wash. Ct. App. 2024).

— Wash. Rev. Code § 4.28.185(1)(d) — 1 case

Osborne v. City of Spokane, 738 P.2d 1072 (Wash. Ct. App. 1987).

— Wash. Rev. Code § 4.28.185(1)(e) — 2 cases

Lake v. Butcher, 679 P.2d 409 (Wash. Ct. App. 1984).

In Re The Parentage Of Nld., Ryan Adam Dixon, V. Matthew Goguen (Wash. Ct. App. 2022).

— Wash. Rev. Code § 4.28.185(1)(f) — 2 cases

In Re the Marriage of Corrie, 648 P.2d 501 (Wash. Ct. App. 1982).

In Re Marriage of Robinson, 248 P.3d 532 (Wash. Ct. App. 2011).

— Wash. Rev. Code § 4.28.185(2) — 13 cases

Ralph's Concrete v. Concord Concrete Pumps, 225 P.3d 1035 (Wash. Ct. App. 2010). “¶ 1 At issue is whether service of process by mail on a foreign corporation pursuant to Superior Court Civil Rule (CR) 4(i)(1)(D) is sufficient to confer personal jurisdiction in Washington courts where personal service under the long arm statute, RCW 4.28.185, was not made.…”

Ralph's Concrete Pumping, Inc. v. Concord Concrete Pumps, Inc., 154 Wash. App. 581 (Wash. Ct. App. 2010). “¶1 At issue is whether service of process by mail on a foreign corporation pursuant to Superior Court Civil Rule (CR) 4(i)(l)(D) is sufficient to confer personal jurisdiction in Washington courts where personal service under the long-arm statute, RCW 4.28.185, was not made.…”

Schell v. Tri-State Irrigation, 591 P.2d 1222 (Wash. Ct. App. 1979).

Kysar v. Lambert, 887 P.2d 431 (Wash. Ct. App. 1995).

State Ex Rel. Coughlin v. Jenkins, 7 P.3d 818 (Wash. Ct. App. 2000).

— Wash. Rev. Code § 4.28.185(2)(4) — 1 case

Meeker Ct Condo Assoc., Summerhill Rental Mngmt Llc, App. v. Nicole Gonzales, Res. (Wash. Ct. App. 2018).

— Wash. Rev. Code § 4.28.185(3) — 6 cases

John Does v. CompCare, Inc., 763 P.2d 1237 (Wash. Ct. App. 1988).

Air Serv Corp. & Abm Aviation, Inc. v. John E. Montgomery, 446 P.3d 659 (Wash. Ct. App. 2019).

In Re Marriage of Tsarbopoulos, 104 P.3d 692 (Wash. Ct. App. 2004).

Nam Chuong Huynh, Appellant/cr-respondent v. Aker Biomarine Antarctic As, Respondent/cr-appellant (Wash. Ct. App. 2017).

— Wash. Rev. Code § 4.28.185(4) — 33 cases

Barr v. Interbay Citizens Bank of Tampa, 649 P.2d 827 (Wash. 1982).

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

ShareBuilder Sec. Corp. v. Hoang, 137 Wash. App. 330 (Wash. Ct. App. 2007).

— Wash. Rev. Code § 4.28.185(5) — 84 cases

Scott Fetzer Co. v. Weeks, 786 P.2d 265 (Wash. 1990). “The principal issue presented for decision is whether the fees awards provision of Washington's long-arm statute, RCW 4.28.185(5), authorizes an award of attorney fees when a foreign defendant prevails on jurisdictional grounds.”

Scott Fetzer Co. v. Weeks, 859 P.2d 1210 (Wash. 1993). “[AJwards of attorney fees under RCW 4.28.185(5) have become all-or-nothing propositions, with trial court decisions accorded unquestioned deference so long as lip service has been paid to the notions of fair play and substantiál justice.”

Kim v. Lakeside Adult Fam. Home, 374 P.3d 121 (Wash. 2016). “While Kim attempted service under RCW 4.28.185, see CP at 1246-48, Thomas has not yet “prevailed in the action.”

Biggs v. Vail, 876 P.2d 448 (Wash. 1994).

Lundberg v. Coleman, 60 P.3d 595 (Wash. Ct. App. 2002).

— Wash. Rev. Code § 4.28.185(6) — 3 cases

Ford Servs., Llc v. The City Of Sedro-wooley (Wash. Ct. App. 2015).

— Wash. Rev. Code § 4.28.185(a) — 2 cases

Tyee Constr. Co. v. Dulien Steel Prods., Inc., 381 P.2d 245 (Wash. 1963).

Carrigan v. California Horse Racing Bd., 802 P.2d 813 (Wash. Ct. App. 1990).

— Wash. Rev. Code § 4.28.185(b) — 1 case

Swartwood v. Fun-Tastic Shows Inc (W.D. Wash. 2020).

— Wash. Rev. Code § 4.28.185(b)(1) — 1 case

Grange Ins. v. State, 744 P.2d 366 (Wash. Ct. App. 1987).

— Wash. Rev. Code § 4.28.185(d) — 1 case

Teck Metals, Ltd. v. Certain Underwriters at Lloyd's, 735 F. Supp. 2d 1231 (E.D. Wash. 2010).

— Wash. Rev. Code § 4.28.185(l)(a) — 18 cases

Failla v. FixtureOne Corp., 336 P.3d 1112 (Wash. 2014).

SeaHAVN, Ltd. v. Bank, 154 Wash. App. 550 (Wash. Ct. App. 2010). “appeals the trial court’s decision to dismiss its breach of contract lawsuit against an Icelandic bank, Glitnir Bank, for lack of personal jurisdiction under Washington’s long-arm statute, RCW 4.28.185. SeaHAVN contends that based on the execution of a nondisclosure agreement in…”

Raymond v. Robinson, 104 Wash. App. 627 (Wash. Ct. App. 2001).

Harbison v. Garden Valley Outfitters, Inc., 849 P.2d 669 (Wash. Ct. App. 1993).

— Wash. Rev. Code § 4.28.185(l)(b) — 12 cases

Harbison v. Garden Valley Outfitters, Inc., 849 P.2d 669 (Wash. Ct. App. 1993).

Walker v. Bonney-watson Co., 823 P.2d 518 (Wash. Ct. App. 1992).

In Re the Marriage of Hall, 607 P.2d 898 (Wash. Ct. App. 1980).

— Wash. Rev. Code § 4.28.185(l)(c) — 1 case

In re the Marriage of David-Oytan, 288 P.3d 57 (Wash. Ct. App. 2012). “Kudret also claims he did not have sufficient contacts with the state to satisfy due process and the court should have declined to exercise personal jurisdiction over him as a matter of equity. *798 1. Long-Arm Statute ¶44 Extending the jurisdiction of Washington courts to…”

— Wash. Rev. Code § 4.28.185(l)(d) — 1 case

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

— Wash. Rev. Code § 4.28.185(l)(e) — 2 cases

In Re the Marriage of Myers, 594 P.2d 902 (Wash. 1979).

— Wash. Rev. Code § 4.28.185(l)(f) — 2 cases

In re the Marriage of Robinson, 248 P.3d 532 (Wash. Ct. App. 2010).

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.