Wash. Rev. Code » Title 43 · Chapter 43.101
Revised Code of Washington

Wash. Rev. Code § 43.101.390 (2026)

Immunity of commission

✓ current as of May 2026
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(1) The commission and individuals acting on behalf of the commission are immune from suit in any civil or criminal action contesting or based upon proceedings or other official acts performed in the course of their duties in the administration and enforcement of this chapter.
(2) Without limiting the generality of the foregoing, the commission and individuals acting on behalf of the commission are immune from suit in any civil action based on the certification, denial of certification, suspension, or other action regarding decertification of peace officers, reserve officers, or corrections officers.
[ 2021 c 323 s 16; 2001 c 167 s 11.]
Notes of Decisions
Cited in 6 cases (4 in the last 5 years), 2013–2026 · leading case: Ent v. Washington State Crim. Just. Training Comm'n, 301 P.3d 468 (Wash. Ct. App. 2013).
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Ent v. Washington State Crim. Just. Training Comm'n, 301 P.3d 468 (Wash. Ct. App. 2013). · cites it 16× “¶1 — RCW 43.101.390 provides the Washington State Criminal Justice Training Commission with broad immunity from suit.”
John Cruz v. City of Spokane, 66 F.4th 1193 (9th Cir. 2023). · cites it 18× “CITY OF SPOKANE 3 SUMMARY ** Civil Rights/Washington Law In an action alleging, in part, wrongful discharge, the panel certified the following question to the Washington Supreme Court: What is the scope of immunity provided by RCW 43.101.390? Specifically, does the provision…”
Michael Salvo, App. V. Washington Crim. Just. Training Comm'n, Et Ano, Resp. (Wash. Ct. App. 2026). · cites it 12× “CJTC moved for dismissal under CR 12(c), claiming immunity under RCW 43.101.390, which the trial court granted.”
Michael Salvo, App. V. Washington Crim. Just. Training Comm'n, Et Ano, Resp. (Wash. Ct. App. 2026). · cites it 12× “CJTC moved for dismissal under CR 12(c), claiming immunity under RCW 43.101.390, which the trial court granted.”
Scott D. Ent, App. v. Wa. St. Crim. Just. Training Comm'n, Res. (Wash. Ct. App. 2013). · cites it 17× “Pursuant to CR 12(c), the trial court dismissed claims for personal injury occurring during graduation exercises at the Commission's academy. We affirm. FACTS The Washington State Criminal Justice Training Commission ("CJTC" or "the Commission") operates a Basic Law Enforcement…”
Cruz v. Ferry Cnty. (E.D. Wash. 2021). · cites it 6× “3 The statute at issue immunizes the Commission and individuals 15 acting on its behalf “in any civil or criminal action contesting or based upon 16 proceedings or other official acts performed in the course of their duties in the 17 18 3 Defendants concede that the statutory…”
— Wash. Rev. Code § 43.101.390(1) — 4 cases
John Cruz v. City of Spokane, 66 F.4th 1193 (9th Cir. 2023). “CITY OF SPOKANE 3 SUMMARY ** Civil Rights/Washington Law In an action alleging, in part, wrongful discharge, the panel certified the following question to the Washington Supreme Court: What is the scope of immunity provided by RCW 43.101.390? Specifically, does the provision…”
Cruz v. Ferry Cnty. (E.D. Wash. 2021). “3 The statute at issue immunizes the Commission and individuals 15 acting on its behalf “in any civil or criminal action contesting or based upon 16 proceedings or other official acts performed in the course of their duties in the 17 18 3 Defendants concede that the statutory…”
Michael Salvo, App. V. Washington Crim. Just. Training Comm'n, Et Ano, Resp. (Wash. Ct. App. 2026). “CJTC moved for dismissal under CR 12(c), claiming immunity under RCW 43.101.390, which the trial court granted.”
Michael Salvo, App. V. Washington Crim. Just. Training Comm'n, Et Ano, Resp. (Wash. Ct. App. 2026). “CJTC moved for dismissal under CR 12(c), claiming immunity under RCW 43.101.390, which the trial court granted.”
— Wash. Rev. Code § 43.101.390(2) — 1 case
Cruz v. Ferry Cnty. (E.D. Wash. 2021). “3 The statute at issue immunizes the Commission and individuals 15 acting on its behalf “in any civil or criminal action contesting or based upon 16 proceedings or other official acts performed in the course of their duties in the 17 18 3 Defendants concede that the statutory…”
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