Revised Code of Washington
Wash. Rev. Code § 48.18.200 (2026)
Limiting actions, jurisdiction
✓ current as of May 2026
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(1) Except as provided by subsection (3) of this section, no insurance contract delivered or issued for delivery in this state and covering subjects located, resident, or to be performed in this state, shall contain any condition, stipulation, or agreement
(a) requiring it to be construed according to the laws of any other state or country except as necessary to meet the requirements of the motor vehicle financial responsibility laws of such other state or country; or
(b) depriving the courts of this state of the jurisdiction of action against the insurer; or
(c) limiting right of action against the insurer to a period of less than one year from the time when the cause of action accrues in connection with all insurances other than property and marine and transportation insurances. In contracts of property insurance, or of marine and transportation insurance, such limitation shall not be to a period of less than one year from the date of the loss.
(2) Any such condition, stipulation, or agreement in violation of this section shall be void, but such voiding shall not affect the validity of the other provisions of the contract.
[ 2019 c 427 s 29; 1947 c 79 s .18.20; Rem. Supp. 1947 s 45.18.20.]
Notes:
Notes of Decisions
Cited in 49
cases (15 in the last 5 years), 1967–2025 · leading case: Dep't of Transp. v. James River Ins., 292 P.3d 118 (Wash. 2013).
Dep't of Transp. v. James River Ins., 292 P.3d 118 (Wash. 2013). “In rendering its deci *394 sion, the trial court held the arbitration clause was barred by RCW 48.18.200 and RCW 48.15.150. The trial court further held that these statutes were not preempted by the FAA based on “reverse preemption” under the McCarranFerguson Act, 15 U.”
Allied Professionals Ins. v. Michael Anglesey, 952 F.3d 1131 (9th Cir. 2020). “Discussion The question certified by the district court is “whether the Liability Risk Retention Act preempts Wash. Rev. Code § 48.18.200 (1)(b) as applied to risk retention groups.”
Schwindt v. Commonwealth Ins. Co., 997 P.2d 353 (Wash. 2000). “at 1, 8-11 (citing RCW 48.18.200(1)(c); RCW 48.18.120(1); WAC 284-20-010(3)).”
Port of Seattle v. Lexington Ins. Co., 48 P.3d 334 (Wash. Ct. App. 2002). “"`" [44] Thus, RCW 48.18.200 and WAC 248-20-010 do not mandate a 12-month limitation period.”
Port of Seattle v. Lexington Ins., 111 Wash. App. 901 (Wash. Ct. App. 2002). “” ’ ” 44 Thus, RCW 48.18.200 and WAC 248-20-010 do not mandate a 12-month limitation period.”
Providence Health & Serv. v. Certain Underwriters, 358 F. Supp. 3d 1195 (W.D. Wash. 2019). “shall contain any condition, stipulation, or agreement requiring it to be construed according to the laws of any other state or country except as necessary to meet the requirements of the motor vehicle financial responsibility laws of such other state or country.”
Panorama Vill. v. Allstate Ins. Co., 26 P.3d 910 (Wash. 2001). “" RCW 48.18.200(1)(c). The California courts have not, however, found this distinction of any significance.”
Panorama Vill. Condo. Owners Ass'n Bd. of Directors v. Allstate Ins., 144 Wash. 2d 130 (Wash. 2001). “” RCW 48.18.200(1)(c). The California courts have not, however, found this distinction of any significance.”
McDonald v. State Farm Fire & Cas. Co., 837 P.2d 1000 (Wash. 1992). “Insurance companies are permitted by statute to limit the insured's right of action against the insurer: In contracts of property insurance .”
Ashburn v. Safeco Ins. Co. of Am., 713 P.2d 742 (Wash. Ct. App. 1986). “To the contrary, in providing that limitation of a *697 right of action in an insurance policy may not be less than 1 year from the date of loss, RCW 48.18.200 impliedly authorizes (but does not require) such a period.”
Karpenski v. Am. Gen. Life Companies, LLC, 999 F. Supp. 2d 1218 (W.D. Wash. 2014). “Plaintiff points to RCW 48.18.200, which voids any clause in an insurance policy “delivered or issued for delivery in this state and covering subjects located, resident, or to be performed in this state” that requires the policy “to be construed according to the laws of any…”
Alcoa v. Aetna Cas. & Sur. Co., 998 P.2d 856 (Wash. 2000). “" RCW 48.18.200(1)(c). In effect, these statutes authorize property insurers to contract for repose provisions of fairly short duration.”
— Wash. Rev. Code § 48.18.200(1) — 4 cases
Ashburn v. Safeco Ins. Co. of Am., 713 P.2d 742 (Wash. Ct. App. 1986). “To the contrary, in providing that limitation of a *697 right of action in an insurance policy may not be less than 1 year from the date of loss, RCW 48.18.200 impliedly authorizes (but does not require) such a period.”
Viet Cuong Nguyen v. Glendale Constr. Co., 782 P.2d 1110 (Wash. Ct. App. 1989).
Schwindt v. Commonwealth Ins., 140 Wash. 2d 348 (Wash. 2000).
Jackson Contractor Grp. Inc v. Travelers Cas. & Sur. Co. of Am. (E.D. Wash. 2022).
— Wash. Rev. Code § 48.18.200(1)(a) — 3 cases
Oak Harbor Freight Lines, Inc. v. Xl Ins. Am., Inc. (Wash. Ct. App. 2017).
Fin. Pac. Leasing Inc v. RVI Am. Ins. Co (W.D. Wash. 2023).
Sterling & Wilson Solar Solutions Inc v. Fid. & Deposit Co. of Maryland (E.D. Wash. 2023).
— Wash. Rev. Code § 48.18.200(1)(b) — 8 cases
Allied Professionals Ins. v. Michael Anglesey, 952 F.3d 1131 (9th Cir. 2020). “Discussion The question certified by the district court is “whether the Liability Risk Retention Act preempts Wash. Rev. Code § 48.18.200 (1)(b) as applied to risk retention groups.”
Oak Harbor Freight Lines, Inc. v. Xl Ins. Am., Inc. (Wash. Ct. App. 2017).
Jackson Contractor Grp. Inc v. Travelers Cas. & Sur. Co. of Am. (E.D. Wash. 2022).
CLMS Mgmt. Servs. Ltd. P'ship v. Amwins Brokerage of Georgia LLC (W.D. Wash. 2019).
Washington Schs. Risk Mgmt. Pool v. Am. Re-Ins. Co. (W.D. Wash. 2023).
— Wash. Rev. Code § 48.18.200(1)(c) — 13 cases
Schwindt v. Commonwealth Ins. Co., 997 P.2d 353 (Wash. 2000). “at 1, 8-11 (citing RCW 48.18.200(1)(c); RCW 48.18.120(1); WAC 284-20-010(3)).”
Panorama Vill. v. Allstate Ins. Co., 26 P.3d 910 (Wash. 2001). “" RCW 48.18.200(1)(c). The California courts have not, however, found this distinction of any significance.”
Panorama Vill. Condo. Owners Ass'n Bd. of Directors v. Allstate Ins., 144 Wash. 2d 130 (Wash. 2001). “” RCW 48.18.200(1)(c). The California courts have not, however, found this distinction of any significance.”
Port of Seattle v. Lexington Ins. Co., 48 P.3d 334 (Wash. Ct. App. 2002). “"`" [44] Thus, RCW 48.18.200 and WAC 248-20-010 do not mandate a 12-month limitation period.”
Port of Seattle v. Lexington Ins., 111 Wash. App. 901 (Wash. Ct. App. 2002). “” ’ ” 44 Thus, RCW 48.18.200 and WAC 248-20-010 do not mandate a 12-month limitation period.”
— Wash. Rev. Code § 48.18.200(2) — 5 cases
GB Auctions Inc. v. Old Repub. Ins. Co., 357 F. Supp. 3d 1087 (E.D. Wash. 2019).
Camper v. State Farm Fire & Cas. Co. (W.D. Wash. 2021).
Schmitt v. Kaiser Found. Health Plan of Washington (W.D. Wash. 2022).
Washington Schs. Risk Mgmt. Pool v. Am. Re-Ins. Co. (W.D. Wash. 2023).
Thomas Miller Specialty Offshore v. Electron Hydro LLC (W.D. Wash. 2025).
— Wash. Rev. Code § 48.18.200(a)(1) — 1 case
Washington Schs. Risk Mgmt. Pool v. Am. Re-Ins. Co. (W.D. Wash. 2023).
— Wash. Rev. Code § 48.18.200(b) — 2 cases
Jackson v. The Aliera Companies Inc (W.D. Wash. 2020).
Jackson v. The Aliera Companies Inc (W.D. Wash. 2020).
— Wash. Rev. Code § 48.18.200(c) — 1 case
McDermed v. Safeco Ins. Co. of Am. (W.D. Wash. 2023).
— Wash. Rev. Code § 48.18.200(l)(a) — 1 case
Dep't of Transp. v. James River Ins., 292 P.3d 118 (Wash. 2013). “In rendering its deci *394 sion, the trial court held the arbitration clause was barred by RCW 48.18.200 and RCW 48.15.150. The trial court further held that these statutes were not preempted by the FAA based on “reverse preemption” under the McCarranFerguson Act, 15 U.”
— Wash. Rev. Code § 48.18.200(l)(b) — 1 case
Dep't of Transp. v. James River Ins., 292 P.3d 118 (Wash. 2013). “In rendering its deci *394 sion, the trial court held the arbitration clause was barred by RCW 48.18.200 and RCW 48.15.150. The trial court further held that these statutes were not preempted by the FAA based on “reverse preemption” under the McCarranFerguson Act, 15 U.”
— Wash. Rev. Code § 48.18.200(l)(c) — 1 case
Schwindt v. Commonwealth Ins., 140 Wash. 2d 348 (Wash. 2000).
— Wash. Rev. Code § 48.18.200(l)(e) — 1 case
Schwindt v. Commonwealth Ins., 140 Wash. 2d 348 (Wash. 2000).
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