Revised Code of Washington
Wash. Rev. Code § 4.84.015 (2026)
✓ current as of May 2026
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(1) In any civil action for the recovery of money only, the plaintiff will be considered the prevailing party for the purpose of awarding costs, including a statutory attorney fee, if: (a) The defendant makes full or partial payment of the amounts sought by the plaintiff prior to the entry of judgment; and (b) before such payment is tendered, the plaintiff has notified the defendant in writing that the full or partial payment of the amounts sued for might result in an award of costs.
(2) For the purposes of this section, "plaintiff" includes a counterclaimant, cross-claimant, and third-party plaintiff, and "defendant" includes a party defending a counterclaim, cross-claim, or third-party claim.
(3) A party may demand, offer, or accept the payment of statutory costs before the entry of judgment in an action.
(4) This section may not be construed to (a) authorize an award of costs if the action is resolved by a negotiated settlement or (b) limit or bar the operation of cost-shifting provisions of other statutes or court rules.
[ 2009 c 240 s 2.]
Notes of Decisions
Cited in 4
cases (3 in the last 5 years), 2012–2022 · leading case: Niccum v. Enquist, 286 P.3d 966 (Wash. 2012).
Niccum v. Enquist, 286 P.3d 966 (Wash. 2012). “RCW 4.84.015 now provides in part: “(1) In any civil action for the recovery of money only, the plaintiff will be considered the prevailing party for the purpose of awarding costs, including a statutory attorney fee, if: (a) The defendant makes full or partial payment of the…”
Marvin Olsen, Et Ux, V. H. Gary Wallis, Et Ux (Wash. Ct. App. 2022). “Fees for Wallis Wallis also seeks attorney fees on appeal, and he provides a separate section of his brief addressing the request for fees under the theory that he should be the prevailing party on appeal under RCW 4.84.015, CR 68, and RAP 14.2 and 18.”
Asset Recovery Grp., Inc., V. Lily Wilson-codega (Wash. Ct. App. 2021). “” This contention lacks merits as it ignores the next subsection of the same statute. RCW 4.84.015(4) instructs: “This section may not be construed to (a) authorize an award of costs if the action is resolved by a negotiated settlement or (b) limit or bar the operation of…”
Riddell v. SB&C Ltd (W.D. Wash. 2022). “§ 4.84.015. 1 confusion that might result is mitigated by SBC’s cover letter for the same document, which states 2 that the document is “a detailed breakdown of the amounts that Plaintiff will be asking the court 3 to award judgment for is attached,” id.”
— Wash. Rev. Code § 4.84.015(2) — 1 case
Marvin Olsen, Et Ux, V. H. Gary Wallis, Et Ux (Wash. Ct. App. 2022). “Fees for Wallis Wallis also seeks attorney fees on appeal, and he provides a separate section of his brief addressing the request for fees under the theory that he should be the prevailing party on appeal under RCW 4.84.015, CR 68, and RAP 14.2 and 18.”
— Wash. Rev. Code § 4.84.015(3) — 1 case
Asset Recovery Grp., Inc., V. Lily Wilson-codega (Wash. Ct. App. 2021). “” This contention lacks merits as it ignores the next subsection of the same statute. RCW 4.84.015(4) instructs: “This section may not be construed to (a) authorize an award of costs if the action is resolved by a negotiated settlement or (b) limit or bar the operation of…”
— Wash. Rev. Code § 4.84.015(4) — 1 case
Asset Recovery Grp., Inc., V. Lily Wilson-codega (Wash. Ct. App. 2021). “” This contention lacks merits as it ignores the next subsection of the same statute. RCW 4.84.015(4) instructs: “This section may not be construed to (a) authorize an award of costs if the action is resolved by a negotiated settlement or (b) limit or bar the operation of…”
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