Revised Code of Washington

Wash. Rev. Code § 4.48.020 (2026)

Reference without consent

✓ current as of May 2026

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Where the parties do not consent, the court may upon the application of either party, direct a reference in all cases formerly cognizable in chancery in which reference might be made:

(1) When the trial of an issue of fact shall require the examination of a long account on either side, in which case the referees may be directed to hear and decide the whole issue, or to report upon any specific question of fact involved therein; or,

(2) When the taking of an account shall be necessary for the information of the court, before judgment upon an issue of law, or for carrying a judgment or order into effect; or,

(3) When a question of fact other than upon the pleadings shall arise, upon motion or otherwise, in any stage of the action; or,

(4) When it is necessary for the information of the court in a special proceeding.

[ 1984 c 258 s 513; Code 1881 s 249; 1877 p 51 s 253; 1869 p 61 s 253; 1854 p 168 s 207; RRS s 370.]

Notes:

Court Improvement Act of 1984—Effective dates—Severability—Short title—1984 c 258: See notes following RCW 3.30.010.

Notes of Decisions

Cited in 3 cases, 1992–2016 · leading case: Barnett v. Hicks, 829 P.2d 1087 (Wash. 1992).

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Barnett v. Hicks, 829 P.2d 1087 (Wash. 1992). “010; RCW 4.48.020. Each has different notice requirements.”

Delany v. Canning, 929 P.2d 475 (Wash. Ct. App. 1997). · cites it 2× “Inman as a "master in chancery” pursuant to RCW 4.48.020 was improper because Mr. Inman was not an attorney and had a relationship to other parties.”

Est. Of Mildred G. Johnson (Wash. Ct. App. 2016). · cites it 3× “3? Is he a referee and, therefore, a trier of fact under RCW 4.48.020? All of those—all of those statutes and rules implicate different procedures by which the information or the presentation is preserved in an evidentiary proceeding.”

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.