Wash. Rev. Code » Title 47 · Chapter 47.52
Revised Code of Washington

Wash. Rev. Code § 47.52.041 (2026)

✓ current as of May 2026
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No person, firm or corporation, private or municipal, shall have any claim against the state, city or county by reason of the closing of such streets, roads or highways as long as access still exists or is provided to such property abutting upon the closed streets, roads or highways. Circuity of travel shall not be a compensable item of damage.
[ 1961 c 13 s 47.52.041. Prior: 1955 c 75 s 2.]
Notes of Decisions
Cited in 9 cases, 1961–2016 · leading case: Union Elevator & Warehouse Co. v. State, 980 P.2d 779 (Wash. Ct. App. 1999).
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Union Elevator & Warehouse Co. v. State, 980 P.2d 779 (Wash. Ct. App. 1999). · cites it 3× “It argues the trier of fact should determine whether adequate access to a particular prop *294 erty exists only after taking into consideration other factors such as safety, reasonableness, and commercial practicalities.”
Williams Place, LLC v. State ex rel. Dep't of Transp., 348 P.3d 797 (Wash. Ct. App. 2015). “¶75 The trial court dismissed the suit on summary judgment, finding as a matter of law that Union Elevator still had “access” within the meaning of RCW 47.52.041 and .080, provisions of the limited-access highway code, with the result that statutory compensation was not payable.”
State v. Wineberg, 444 P.2d 787 (Wash. 1968). “Appellant’s property does not abut directly on the portion of the roadway being closed.”
Pande Cameron & Co. of Seattle, Inc. v. Cent. Puget Sound Reg'l Transit Auth., 610 F. Supp. 2d 1288 (W.D. Wash. 2009). “§ 47.52.041 (regarding road closures, “[c]ircuity of travel shall not be a compensable item of damage.”
State v. Kodama, 483 P.2d 857 (Wash. Ct. App. 1971). “The instruction is based upon RCW 47.52.041, which provides that: No person, firm or corporation, private or municipal, shall have any claim against the state, city or county by reason of the closing of such streets, roads or highways as long as access still exists or is…”
Tt Props., Llc v. City Of Tacoma, 366 P.3d 465 (Wash. Ct. App. 2016). “886 (1912); see also RCW 47.52.041 (preventing takings liability for the “closing of such streets, roads or highways as long as access still exists or is provided to such property abutting upon the closed streets, roads or highways.”
Feuerborn v. State, 367 P.2d 143 (Wash. 1961). “The second argument of respondent is based on RCW 47.52.041, which reads as follows: “No person, firm or corporation, private or municipal, shall have any claim against the state, city or county by reason of the closing of such streets, roads or highways as long as access still…”
Jon Gibson, et ux v. City of Spokane Valley (Wash. Ct. App. 2013). “Moreover, RCW 47.52.041 provides that no person shall have any claim against a city, state, or county "by reason of the closing of such streets, roads or highways as long as access still exists or is provided to such property abutting upon the closed streets, roads or highways.”
Williams Place, LLC v. State of Washington, Dep't of Transp. (Wash. Ct. App. 2015). “The trial court dismissed the suit on summary judgment, finding as a matter of law that Union Elevator still had "access" within the meaning ofRCW 47.52.041 and .080, provisions of the limited-access highway code, with the result that statutory compensation was not payable.”
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