Revised Code of Washington

Wash. Rev. Code § 4.28.210 (2026)

Appearance, what constitutes

✓ current as of May 2026
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A defendant appears in an action when he or she answers, demurs, makes any application for an order therein, or gives the plaintiff written notice of his or her appearance. After appearance a defendant is entitled to notice of all subsequent proceedings; but when a defendant has not appeared, service of notice or papers in the ordinary proceedings in an action need not be made upon him or her. Every such appearance made in an action shall be deemed a general appearance, unless the defendant in making the same states that the same is a special appearance.
[ 2011 c 336 s 102; 1893 c 127 s 16; RRS s 241.]

Notes:

Rules of court: Demurrers abolishedCR 7(c).
Notes of Decisions
Cited in 70 cases (14 in the last 5 years), 1953–2026 · leading case: Morin v. Burris, 161 P.3d 956 (Wash. 2007).
Morin v. Burris, 161 P.3d 956 (Wash. 2007). · cites it 2× “¶ 34 Formal appearances are governed by RCW 4.28.210, but we have recognized that the statutory methods of appearance are not exhaustive and that there are other, informal, ways in which a party may appear.”
Morin v. Burris, 160 Wash. 2d 745 (Wash. 2007). · cites it 2× “¶34 Formal appearances are governed by RCW 4.28.210, but we have recognized that the statutory methods of appearance are not exhaustive and that there are other, informal ways in which a party may appear.”
Leen v. Demopolis, 815 P.2d 269 (Wash. Ct. App. 1991). · cites it 3× “Under RCW 4.28.210 "[a] defendant appears in an action when he answers, demurs, makes any application for an order therein, or gives the plaintiff written notice of his appearance.”
Tiffin v. Hendricks, 271 P.2d 683 (Wash. 1954). · cites it 4× “(3) That a default judgment entered against a defendant who has appeared in a case in this manner is tantamount to a void-judgment if the defendant is not in default and if no notice has been given the defendant as required by RCW 4.28.210. (4) That a defendant against whom a…”
Batterman v. Red Lion Hotels, Inc., 21 P.3d 1174 (Wash. Ct. App. 2001). · cites it 2× “" RCW 4.28.210. But the methods set forth in RCW 4.”
Batterman v. Red Lion Hotels, Inc., 106 Wash. App. 54 (Wash. Ct. App. 2001). · cites it 2× “” RCW 4.28.210. But the methods set forth in RCW 4.”
Servatron, Inc. v. Intelligent Wireless Prods., Inc., 346 P.3d 831 (Wash. Ct. App. 2015). · cites it 2× “RCW 4.28.210 states: A defendant appears in an action when he or she answers, demurs, makes any application for an order therein, or gives the plaintiff written notice of his or her appearance.”
Prof'l Marine Co. v. Those Certain Underwriters, 77 P.3d 658 (Wash. Ct. App. 2003). · cites it 2× “” RCW 4.28.210. But the methods set forth in RCW 4.”
Gage v. Boeing Co., 776 P.2d 991 (Wash. Ct. App. 1989). · cites it 2× “Washington's appearance statute, RCW 4.28.210, provides: A defendant appears in an action when he answers, .”
Matia Inv. Fund, Inc. v. City of Tacoma, 119 P.3d 391 (Wash. Ct. App. 2005). · cites it 4× “¶14 RCW 4.28.210 provides that a party “appears” in an action at the time the party “answers, demurs, makes any application for an order therein, or gives the plaintiff written notice of his appearance.”
City of Des Moines v. Pers. Prop. Identified as $81,231 in United States Currency, 943 P.2d 669 (Wash. Ct. App. 1997). · cites it 2× “” RCW 4.28.210. The methods set forth in RCW 4.”
Shreve v. Chamberlin, 832 P.2d 1355 (Wash. Ct. App. 1992). · cites it 2× “What constitutes an appearance is described in general terms in RCW 4.28.210. That statute provides in part: A defendant appears in an action when he answers, demurs, makes any application for an order therein, or gives the plaintiff written notice of his appearance.”
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