Revised Code of Washington
Wash. Rev. Code § 4.84.270 (2026)
✓ current as of May 2026
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The defendant, or party resisting relief, shall be deemed the prevailing party within the meaning of RCW 4.84.250, if the plaintiff, or party seeking relief in an action for damages where the amount pleaded, exclusive of costs, is equal to or less than the maximum allowed under RCW 4.84.250, recovers nothing, or if the recovery, exclusive of costs, is the same or less than the amount offered in settlement by the defendant, or the party resisting relief, as set forth in RCW 4.84.280.
Notes:
Effective date—1980 c 94: See note following RCW 4.84.250.
Notes of Decisions
Cited in 69
cases (6 in the last 5 years), 1978–2024 · leading case: AllianceOne Receivables Mgmt., Inc. v. Lewis, 325 P.3d 904 (Wash. 2014).
AllianceOne Receivables Mgmt., Inc. v. Lewis, 325 P.3d 904 (Wash. 2014). “270 since under RCW 4.84.270 a defendant is a prevailing party when the plaintiff “recovers nothing.”
Crossroads Mgmt., LLC v. Ridgway, 540 P.3d 82 (Wash. 2023). “RCW 4.84.270. Because the Lewises’ could not recover more in damages than $1,695 and the Ridgways’ settlement offer exceeded that amount, the arbitrator awarded the Ridgways $14,386 in attorney fees and costs.”
Williams v. Tilaye, 272 P.3d 235 (Wash. 2012). “Alternatively, the defendant can be the prevailing party if either the plaintiff recovers nothing or the defendant makes an offer 10 days or more before trial and the plaintiff recovers as much as or less *62 than that offer.”
Sherman v. Kissinger, 146 Wash. App. 855 (Wash. Ct. App. 2008). “Under RCW 4.84.270, the defendant is the prevailing party if the “amount pleaded” in the plaintiff’s complaint is $10,000 or less and the defendant made a settlement offer equal to or greater than the amount the plaintiff recovers at trial.”
Sherman v. Kissinger, 195 P.3d 539 (Wash. Ct. App. 2008). “Under RCW 4.84.270, the defendant is the prevailing party if the "amount pleaded" in the plaintiff's complaint is $10,000 or less and the defendant made a *550 settlement offer equal to or greater than the amount the plaintiff recovers at trial.”
Sunkidd Venture, Inc. v. Snyder-Entel, 941 P.2d 16 (Wash. Ct. App. 1997). “Her offer to settle pursuant to RCW 4.84.270 [4] for $500 was declined. The case was tried to the district court in March 1995.”
Singer v. Etherington, 789 P.2d 108 (Wash. Ct. App. 1990). “*546 Attorney Fees Singer urges the court to hold that when an offer of settlement is made by a defendant prior to arbitration and the plaintiff prevails, the offer "lapses" for purposes of awarding attorney fees pursuant to RCW 4.84.270 2 upon trial de novo if the defendant…”
Kingston Lumber Supply Co. v. High Tech Dev. Inc., 765 P.2d 27 (Wash. Ct. App. 1988). “RCW 4.84.270. 4 *Thus, even where no settlement offer is made, a defendant is entitled to attorney's fees if the plaintiff recovers nothing.”
Reynolds v. Hicks, 134 Wash. 2d 491 (Wash. 1998). “250 are to be awarded to the prevailing party if the pleading party sought damages, exclusive of costs, of $10,000 or less.”
Reynolds v. Hicks, 951 P.2d 761 (Wash. 1998). “250 are to be awarded to the prevailing party if the pleading party sought damages, exclusive of costs, of $10,000 or less.”
Schmerer v. Darcy, 910 P.2d 498 (Wash. Ct. App. 1996). “250 and RCW 4.84.270 because she offered to settle prior to trial and the Darcys refused.”
Realm, Inc. v. City of Olympia, 277 P.3d 679 (Wash. Ct. App. 2012). “250 provides that in an action for damages for $10,000 or less, “there shall be taxed and allowed to the prevailing party as a part of the costs of the action a reasonable amount to be fixed by the court as attorneys’ fees.”
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