Revised Code of Washington

Wash. Rev. Code § 48.05.200 (2026)

✓ current as of May 2026
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(1) Each authorized foreign or alien insurer must appoint the commissioner as its attorney to receive service of, and upon whom must be served, all legal process issued against it in this state upon causes of action arising within this state. Service upon the commissioner as attorney constitutes service upon the insurer. Service of legal process against the insurer can be had only by service upon the commissioner, except actions upon contractor bonds pursuant to RCW 18.27.040, where service may be upon the department of labor and industries.
(2) With the appointment the insurer must designate by name, email address, and address the person to whom the commissioner must forward legal process so served upon him or her. The insurer may change the person by filing a new designation.
(3) The insurer must keep the designation, address, and email address filed with the commissioner current.
(4) The appointment of the commissioner as attorney is irrevocable, binds any successor in interest or to the assets or liabilities of the insurer, and remains in effect as long as there is in force in this state any contract made by the insurer or liabilities or duties arising therefrom.
(5) The service of process must be accomplished and processed in the manner prescribed under RCW 48.02.200.
[ 2011 c 47 s 5; 1985 c 264 s 3; 1947 c 79 s .05.20; Rem. Supp. 1947 s 45.05.20.]
Notes of Decisions
Cited in 22 cases (9 in the last 5 years), 1957–2025 · leading case: Ohio Sec. Ins. Co. v. AXIS Ins. Co., 413 P.3d 1028 (Wash. 2018).
Ohio Sec. Ins. Co. v. AXIS Ins. Co., 413 P.3d 1028 (Wash. 2018). · cites it 17× “200, and RCW 48.05.200 establish service through the Washington State Insurance Commissioner as a uniform and exclusive means of service for authorized foreign or alien insurers in Washington State?" Order Certifying Question to Wash.”
Thomas Anderson v. State Farm Mut. Auto. Ins., 917 F.3d 1126 (9th Cir. 2019). · cites it 4× “RCW 48.05.200(1). To serve legal process on State Farm, the Andersons served the Commissioner, who forwarded the complaint to State Farm’s designated recipient.”
Topliff v. Chicago Ins., 130 Wash. App. 301 (Wash. Ct. App. 2005). · cites it 6× “The Topliffs’ contend, despite the lack of notice to CIC, that CIC was properly served under RCW 48.05.200. We agree with the trial court that under these extraordinary facts, CIC was deprived of the opportunity to respond resulting in a failure of due process.”
Trinity Universal Ins. v. Ohio Cas. Ins., 312 P.3d 976 (Wash. Ct. App. 2013). · cites it 2× “See RCW 48.05.200 (requiring service on foreign insurer to be on insurance commissioner); RCW 48.”
Topliff v. Chicago Ins. Co., 122 P.3d 922 (Wash. Ct. App. 2005). · cites it 6× “The Topliffs' contend, despite the lack of notice to CIC that they were properly served under RCW 48.05.200. We agree with the trial court that under these extraordinary facts, CIC was deprived of the opportunity to respond resulting in a failure of due process.”
Prest v. Am. Bankers Life Assurance Co., 900 P.2d 595 (Wash. Ct. App. 1995). “” 2 RCW 48.05.200(1) provides that service upon the commissioner shall constitute service upon the insurer.”
Reiner v. Pittsburg Des Moines Corp., 680 P.2d 55 (Wash. 1984). “, RCW 48.05.200, 48.05.215, or by publication of the summons in a newspaper printed and published in the county where the action is brought, RCW 4.”
In Re Breese's Est., 317 P.2d 1055 (Wash. 1957). “The insurer admits that it has consented to the service of process on the insurance commissioner in compliance with RCW 48.05.200, which provides in part: ■“Each authorized foreign or alien insurer shall appoint the commissioner as its attorney to receive service of, and upon…”
Kiblen v. Mut. of Omaha Ins., 708 P.2d 1215 (Wash. Ct. App. 1985). · cites it 3× “RCW 48.05.200. Thus, a plaintiff in this state would serve the Insurance Commissioner who was then required to effect the service upon the foreign insurer.”
Nathaniel D. Cumming, Apps v. United Servs. Auto. Assoc., Resp (Wash. Ct. App. 2020). · cites it 4× “52913-1-II as required by RCW 48.05.200(1), and service was accepted on March 9, 2018.”
Junior v. GEICO Ins. Agency LLC (W.D. Wash. 2023). · cites it 4× “080 (service against an 23 authorized foreign insurance company must be conducted pursuant to RCW 48.05.200). 24 OIC then forwards the service documents to the foreign insurer.”
Jason Gates & Amanda Gates, V. Homesite Ins. Co. (Wash. Ct. App. 2023). · cites it 3× “4 1 The OIC is a statutorily designated registered agent for Homesite under RCW 48.05.200. 2 RCW 48.30.015(8)(a). 3 RCW 48.”
— Wash. Rev. Code § 48.05.200(1) — 15 cases
Ohio Sec. Ins. Co. v. AXIS Ins. Co., 413 P.3d 1028 (Wash. 2018). “200, and RCW 48.05.200 establish service through the Washington State Insurance Commissioner as a uniform and exclusive means of service for authorized foreign or alien insurers in Washington State?" Order Certifying Question to Wash.”
Thomas Anderson v. State Farm Mut. Auto. Ins., 917 F.3d 1126 (9th Cir. 2019). “RCW 48.05.200(1). To serve legal process on State Farm, the Andersons served the Commissioner, who forwarded the complaint to State Farm’s designated recipient.”
Topliff v. Chicago Ins., 130 Wash. App. 301 (Wash. Ct. App. 2005). “The Topliffs’ contend, despite the lack of notice to CIC, that CIC was properly served under RCW 48.05.200. We agree with the trial court that under these extraordinary facts, CIC was deprived of the opportunity to respond resulting in a failure of due process.”
Trinity Universal Ins. v. Ohio Cas. Ins., 312 P.3d 976 (Wash. Ct. App. 2013). “See RCW 48.05.200 (requiring service on foreign insurer to be on insurance commissioner); RCW 48.”
Prest v. Am. Bankers Life Assurance Co., 900 P.2d 595 (Wash. Ct. App. 1995). “” 2 RCW 48.05.200(1) provides that service upon the commissioner shall constitute service upon the insurer.”
— Wash. Rev. Code § 48.05.200(2) — 1 case
Junior v. GEICO Ins. Agency LLC (W.D. Wash. 2023). “080 (service against an 23 authorized foreign insurance company must be conducted pursuant to RCW 48.05.200). 24 OIC then forwards the service documents to the foreign insurer.”
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