Revised Code of Washington

Wash. Rev. Code § 4.56.115 (2026)

✓ current as of May 2026
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Judgments founded on the tortious conduct of the state of Washington or of the political subdivisions, municipal corporations, and quasi municipal corporations of the state, whether acting in their governmental or proprietary capacities, shall bear interest from the date of entry at two percentage points above the equivalent coupon issue yield (as published by the board of governors of the federal reserve system) of the average bill rate for twenty-six week treasury bills as determined at the first bill market auction conducted during the calendar month immediately preceding the date of entry thereof. In any case where a court is directed on review to enter judgment on a verdict or in any case where a judgment entered on a verdict is wholly or partly affirmed on review, interest on the judgment or on that portion of the judgment affirmed shall date back to and shall accrue from the date the verdict was rendered.
[ 2004 c 185 s 1; 1983 c 147 s 2; 1975 c 26 s 1.]

Notes:

ApplicationInterest accrual2004 c 185: "The rate of interest required by sections 1 and 2(3), chapter 185, Laws of 2004 applies to the accrual of interest:
(1) As of the date of entry of judgment with respect to a judgment that is entered on or after June 10, 2004;
(2) As of June 10, 2004, with respect to a judgment that was entered before June 10, 2004, and that is still accruing interest on June 10, 2004." [ 2004 c 185 s 3.]
Application1983 c 147: See note following RCW 4.56.110.
Notes of Decisions
Cited in 17 cases (2 in the last 5 years), 1977–2025 · leading case: Allstot v. Edwards, 114 Wash. App. 625 (Wash. Ct. App. 2002).
Allstot v. Edwards, 114 Wash. App. 625 (Wash. Ct. App. 2002). · cites it 2× “He also contends that under the common law, his interest on the entire amount due is justified because this amount could have been computed with exactness.”
Allstot v. Edwards, 60 P.3d 601 (Wash. Ct. App. 2002). · cites it 2× “He also contends that under the common law, his interest on the entire amount due is justified because this amount could have been computed with exactness.”
Foster v. Dep't of Transp., 115 P.3d 1029 (Wash. Ct. App. 2005). · cites it 4× “5 ¶9 In 1975, the legislature abrogated Fosbre and waived sovereign immunity from postjudgment interest by enacting RCW 4.56.115. As later amended, RCW 4.56.”
State v. Turner, 59 P.3d 711 (Wash. Ct. App. 2002). · cites it 2× “Turner also suggests that he is entitled to prejudgment interest under RCW 4.56.115 because the reimbursement of the judgment here is “akin to a remedy in tort.”
Teevin v. Wyatt, 876 P.2d 944 (Wash. Ct. App. 1994). · cites it 5× “[defense counsel]: Well, Your Honor, in our memorandum, we make the argument on Page 3, municipal corporations cannot be held to prejudgment interest [under] RCW 4.56.115. I’m reading now. "To argue that this rule is inapplicable here because defendant Wyatt has not been…”
Andrade v. State, 448 A.2d 1293 (R.I. 1982). “Wash. Rev. Code Ann. § 4.56.115 (West Supp.”
Architectural Woods, Inc. v. State, 598 P.2d 1372 (Wash. 1979). “3 Notably, after Fosbre v. State, 76 Wn.2d 255 , 456 P.2d 335 (1969), was decided, the legislature passed a statute to allow the recovery of interest from the state in tort actions.”
State v. Thiessen, 946 P.2d 1207 (Wash. Ct. App. 1997). · cites it 4× “110, nor RCW 4.56.115 requires the State to pay interest under these circumstances.”
Espinoza v. City of Everett, 943 P.2d 387 (Wash. Ct. App. 1997). “2d 944 (1994); RCW 4.56.115. The tort of conversion occurs when one intentionally and unlawfully deprives an owner of possession of a chattel.”
Norris v. State, 733 P.2d 231 (Wash. Ct. App. 1987). “RCW 4.56.115 provides, in part: Interest on judgments against state, political subdivisions or municipal corporations—Torts.”
Kringel v. Dep't of Soc. & Health Servs., 726 P.2d 58 (Wash. Ct. App. 1986). “, RCW 4.56.115 (tort actions); RCW 51.32.080 (industrial insurance); RCW 82.”
Dep't of Corr. v. Fluor Daniel, Inc., 126 P.3d 52 (Wash. Ct. App. 2005). “110(4) and RCW 4.56.115 (“[W]here a *635 court is directed on review to enter judgment.”
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