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:
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). “¶ 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). “¶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). “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). “(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). “" 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). “” 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). “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). “” RCW 4.28.210. But the methods set forth in RCW 4.”
Gage v. Boeing Co., 776 P.2d 991 (Wash. Ct. App. 1989). “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). “¶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). “” RCW 4.28.210. The methods set forth in RCW 4.”
Shreve v. Chamberlin, 832 P.2d 1355 (Wash. Ct. App. 1992). “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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