Revised Code of Washington
Wash. Rev. Code § 48.18.190 (2026)
Policy must contain entire contract
✓ current as of May 2026
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No agreement in conflict with, modifying, or extending any contract of insurance shall be valid unless in writing and made a part of the policy.
[1947 c 79 s .18.19; Rem. Supp. 1947 s 45.18.19.]
Notes of Decisions
Cited in 15
cases, 1957–2020 · leading case: Denny's Restaurants, Inc. v. Sec. Union Title Ins., 859 P.2d 619 (Wash. Ct. App. 1993).
Denny's Restaurants, Inc. v. Sec. Union Title Ins., 859 P.2d 619 (Wash. Ct. App. 1993). “The terms sought to be proved in this case do not conflict, modify, or extend the policy of title insurance; rather they elucidate unexpressed consistent policy terms.”
Gail Michelman v. Lincoln Nat'l Life Insuranc, 685 F.3d 887 (9th Cir. 2012). “See Wash. Rev. Code § 48.18.190 (“No agreement in conflict with, modifying, or extending any contract of Insurance shall be valid unless in writing and made a part of the policy.”
Cont'l Ins. v. Paccar, Inc., 614 P.2d 675 (Wash. Ct. App. 1980). “Continental's argument as to considering prior and contemporaneous agreements and the circumstances leading up to and surrounding the policy's execution is met by the bar of RCW 48.18.190, which provides: Policy must contain entire contract.”
Richter, Wimberley & Ericson, P.S. v. Honore, 628 P.2d 1311 (Wash. Ct. App. 1981). “He additionally asserts the endorsement attempts to incorporate by reference the arbitration agreement in violation of RCW 48.18.190. 8 These arguments are without merit.”
Ross v. State Farm Mut. Auto. Ins. Co., 940 P.2d 252 (Wash. 1997). “The court stated "Such use by [plaintiff] is not the sporadic, isolated incidence of driving of an noncovered car that was contemplated in the clause.").”
Van Noy v. State Farm Mut. Auto. Ins., 983 P.2d 1129 (Wash. Ct. App. 1999). “See RCW 48.18.190, policy must contain the entire contract.”
Sears, Roebuck & Co. v. Hartford Accident & Indem. Co., 313 P.2d 347 (Wash. 1957). “RCW 48.18.190]. We come now to the question of whether Sears gave timely notice to Hartford and complied with the requirement to immediately forward to the company the summons or other process received by it.”
Van Noy v. State Farm Mut. Auto. Ins. Co., 983 P.2d 1129 (Wash. Ct. App. 1999). “[9] See RCW 48.18.190, policy must contain the entire contract.”
Safeco Ins. v. Dairyland Mut. Ins., 446 P.2d 568 (Wash. 1968). “Nor could this written contract of insurance be modified to add a driver age restriction to it.”
NAT. IND. CO., INC. v. Smith-Gandy, Inc., 309 P.2d 742 (Wash. 1957). “RCW 48.18.190], provides: “No agreement in conflict with, modifying, or extending any contract of insurance shall be valid unless in writing and made a part of the policy.”
Leslie v. Fid. Nat'l Title Ins., 598 F. Supp. 2d 1176 (W.D. Wash. 2009). “In its motion to dismiss, Fidelity argued that this claim fails because (1) the claim is barred by RCW 48.18.190 which prohibits modification of an insurance policy except by writing, (2) Plaintiff failed to plead any meeting of the minds or mutual assent, and (3) there could be…”
West Am. Ins. Co. v. State Farm Mut., 480 P.2d 537 (Wash. Ct. App. 1971). “It does not appear that this intent was expressed to, or accepted by, respondent as the other contracting party prior to the time the cause of action, if any, arose under the terms of the insurance policy. An intent of one party to a contract not communicated to the other party…”
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