Wash. Rev. Code » Title 4 · Chapter 4.84
Revised Code of Washington

Wash. Rev. Code § 4.84.280 (2026)

✓ current as of May 2026
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Offers of settlement shall be served on the adverse party in the manner prescribed by applicable court rules at least ten days prior to trial. Offers of settlement shall not be served until thirty days after the completion of the service and filing of the summons and complaint. Offers of settlement shall not be filed or communicated to the trier of the fact until after judgment, at which time a copy of said offer of settlement shall be filed for the purposes of determining attorneys' fees as set forth in RCW 4.84.250.
[ 1983 c 282 s 1; 1980 c 94 s 3; 1973 c 84 s 4.]

Notes:

Effective date—1980 c 94: See note following RCW 4.84.250.
Notes of Decisions
Cited in 62 cases (2 in the last 5 years), 1978–2021 · leading case: Hanson v. Estell, 997 P.2d 426 (Wash. Ct. App. 2000).
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Hanson v. Estell, 997 P.2d 426 (Wash. Ct. App. 2000). · cites it 9× “In June 1997, the Hansons made an offer of settlement pursuant to RCW 4.84.280. The offer was served on the Estells more than 30 days after service of the summons and complaint and more than 10 days before trial, in compliance with the statute.”
Hanson v. Estell, 100 Wash. App. 281 (Wash. Ct. App. 2000). · cites it 8× “In June 1997, the Hansons made an offer of settlement pursuant to RCW 4.84.280. The offer was served on the Estells more than 30 days after service of the summons and complaint and more than 10 days before trial, in compliance with the statute.”
Frank Coluccio Constr. Co. v. King Cnty., 150 P.3d 1147 (Wash. Ct. App. 2007). · cites it 3× “250 through RCW 4.84.280. Absher Constr. Co. v. Kent Sch.”
Williams v. Tilaye, 272 P.3d 235 (Wash. 2012). · cites it 3× “In other words, they argue the plaintiff may invoke the statutory scheme by making an offer of settlement under RCW 4.84.280 for the first time after arbitration but 10 days before trial de novo.”
AllianceOne Receivables Mgmt., Inc. v. Lewis, 325 P.3d 904 (Wash. 2014). · cites it 3× “) Under RCW 4.84.280, settlement offers must be made at least 10 days before a trial begins and may not be conveyed to the judge until after final judgment is rendered.”
Beckmann v. Spokane Transit Auth., 733 P.2d 960 (Wash. 1987). · cites it 4× “The settlement expressly stated that it was made pursuant to RCW 4.84.280, and was not filed with the superior court.”
Hernandez v. Stender, 358 P.3d 1169 (Wash. Ct. App. 2014). · cites it 3× “2d 426 (2000), the court reversed an attorney fee award under RCW 4.84.280. RCW 4.84.280 shares similar language with RCW 7.”
Target Nat'l Bank v. Higgins, 321 P.3d 1215 (Wash. Ct. App. 2014). · cites it 5× “RCW 4.84.280 outlines the procedure for a settlement offer and requires that the offer be made at least 10 days prior to trial.”
Dussault v. Seattle Pub. Schs., 850 P.2d 581 (Wash. Ct. App. 1993). · cites it 5× “Eleven days before trial, on October 24, 1991, the District served Hodson's counsel with an offer of judgment pursuant to CR 68 and RCW 4.84.280. On November 4, 1991, the day of trial, Hodson served a written acceptance of the offer.”
Do v. Farmer, 110 P.3d 840 (Wash. Ct. App. 2005). · cites it 3× “[16] Illustrating the importance of complying with this law, we denied a party attorney fees because the party violated RCW 4.84.280 by communicating too early the existence of a settlement offer.”
Lietz v. Hansen Law Offices, PSC, 271 P.3d 899 (Wash. Ct. App. 2012). · cites it 2× “185 20 and RCW 4.84.280, 21 neither of these statutes applies here.”
Do v. Farmer, 127 Wash. App. 180 (Wash. Ct. App. 2005). · cites it 3× “[ 16 ] Illustrating the importance of complying with this law, we denied a party attorney fees because the party violated RCW 4.84.280 by communicating too early the existence of a settlement offer.”
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