Revised Code of Washington

Wash. Rev. Code § 48.18.460 (2025)

Proof of loss—Furnishing forms—May require oath

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An insurer shall furnish, upon request of any person claiming to have a loss under any insurance contract, forms of proof of loss for completion by such person. But such insurer shall not, by reason of the requirement so to furnish forms, have any responsibility for or with reference to the completion of such proof or the manner of any such completion or attempted completion. If a person makes a claim under a policy of insurance, the insurer may require that the person be examined under an oath administered by a person authorized by state or federal law to administer oaths.
[ 1995 c 285 s 17; 1949 c 190 s 26; 1947 c 79 s .18.46; Rem. Supp. 1949 s 45.18.46.]

Notes:

Effective date—1995 c 285: See RCW 48.30A.900.
Notes of Decisions
Cited in 4 cases (1 in the last 5 years), 2012–2022 · leading case: Allstate Indem. Co. v. Lindquist, No. 2:20-cv-01508 (W.D. Wash. June 17, 2022).
Allstate Indem. Co. v. Lindquist, No. 2:20-cv-01508 (W.D. Wash. June 17, 2022). · cites it 2× “at 2 (quoting 8 Leonhardi Report at 2, 11)); (2) “that RCW 48.18.460 gives insurers the right to demand 9 a ‘proof of loss’ and that state law allows insurers to conduct an [examination under oath 10 (“EOU”)] as part of a ‘proof of loss’” (id.”
Susan Parker v. Allstate Ins. Co., 472 F. App'x 627 (9th Cir. 2012). “The district court erred when it ruled that Parker needed to complete an EUO before she could sue. Washington law provides that an insurance policy can require an insured to be examined under oath, but Washington law does not say that a policyholder cannot sue before the EUO has…”
M. Casey Law, PLLC v. Cole Wathen Leid & Hall, P.c., No. 74601-4 (Wash. Ct. App. Apr. 24, 2017). “"21 There can be no legitimate dispute that RCW 48.18.460, the relevant statute, allows "insurers [to] require that the person be examined under an oath" under appropriate circumstances.”
Pisha v. Safeco Ins. Co. of Am., No. 3:17-cv-05791 (W.D. Wash. Apr. 29, 2020). “Safeco argues that it was justified in requesting an EUO regarding the vandalism 11 claim both under the policy and under RCW 48.18.460 and was prejudiced as a matter of 12 law when Pisha failed to cooperate and attend the EUO.”
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