Revised Code of Washington
Wash. Rev. Code § 48.30.015 (2026)
Unreasonable denial of a claim for coverage or payment of benefits
✓ current as of May 2026
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(1) Any first party claimant to a policy of insurance who is unreasonably denied a claim for coverage or payment of benefits by an insurer may bring an action in the superior court of this state to recover the actual damages sustained, together with the costs of the action, including reasonable attorneys' fees and litigation costs, as set forth in subsection (3) of this section.
(2) The superior court may, after finding that an insurer has acted unreasonably in denying a claim for coverage or payment of benefits or has violated a rule in subsection (5) of this section, increase the total award of damages to an amount not to exceed three times the actual damages.
(3) The superior court shall, after a finding of unreasonable denial of a claim for coverage or payment of benefits, or after a finding of a violation of a rule in subsection (5) of this section, award reasonable attorneys' fees and actual and statutory litigation costs, including expert witness fees, to the first party claimant of an insurance contract who is the prevailing party in such an action.
(4) "First party claimant" means an individual, corporation, association, partnership, or other legal entity asserting a right to payment as a covered person under an insurance policy or insurance contract arising out of the occurrence of the contingency or loss covered by such a policy or contract.
(5) A violation of any of the following is a violation for the purposes of subsections (2) and (3) of this section:
(a) WAC 284-30-330, captioned "specific unfair claims settlement practices defined";
(b) WAC 284-30-350, captioned "misrepresentation of policy provisions";
(c) WAC 284-30-360, captioned "failure to acknowledge pertinent communications";
(d) WAC 284-30-370, captioned "standards for prompt investigation of claims";
(e) WAC 284-30-380, captioned "standards for prompt, fair and equitable settlements applicable to all insurers"; or
(f) An unfair claims settlement practice rule adopted under RCW 48.30.010 by the insurance commissioner intending to implement this section. The rule must be codified in chapter 284-30 of the Washington Administrative Code.
(6) This section does not limit a court's existing ability to make any other determination regarding an action for an unfair or deceptive practice of an insurer or provide for any other remedy that is available at law.
(7) This section does not apply to a health plan offered by a health carrier. "Health plan" has the same meaning as in RCW 48.43.005. "Health carrier" has the same meaning as in RCW 48.43.005.
(8)(a) Twenty days prior to filing an action based on this section, a first party claimant must provide written notice of the basis for the cause of action to the insurer and office of the insurance commissioner. Notice may be provided by regular mail, registered mail, or certified mail with return receipt requested. Proof of notice by mail may be made in the same manner as prescribed by court rule or statute for proof of service by mail. The insurer and insurance commissioner are deemed to have received notice three business days after the notice is mailed.
(b) If the insurer fails to resolve the basis for the action within the twenty-day period after the written notice by the first party claimant, the first party claimant may bring the action without any further notice.
(c) The first party claimant may bring an action after the required period of time in (a) of this subsection has elapsed.
(d) If a written notice of claim is served under (a) of this subsection within the time prescribed for the filing of an action under this section, the statute of limitations for the action is tolled during the twenty-day period of time in (a) of this subsection.
[ 2007 c 498 s 3 (Referendum Measure No. 67, approved November 6, 2007).]
Notes:
Short title—2007 c 498: "This act may be known and cited as the insurance fair conduct act." [ 2007 c 498 s 1.]
Notes of Decisions
Cited in 249
cases (149 in the last 5 years), 2008–2026 · leading case: Perez-Crisantos v. State Farm Fire & Cas. Co., 389 P.3d 476 (Wash. 2017).
Perez-Crisantos v. State Farm Fire & Cas. Co., 389 P.3d 476 (Wash. 2017). “¶1 In 2007, the legislature passed, and the voters of this state ratified, the Insurance Fair Conduct Act (IFCA), RCW 48.30.015. IFCA gives insureds a new cause of action against insurers who unreasonably deny coverage or benefits.”
Langley v. Geico Gen. Ins., 89 F. Supp. 3d 1083 (E.D. Wash. 2015). “The parties dispute what causes of action are available under the IFCA, codified at RCW 48.30.015. To determine what causes of action are available, the Court must turn to any controlling Washington Supreme Court precedent interpreting the applicable statute.”
Ainsworth v. Progressive Cas. Ins., 322 P.3d 6 (Wash. Ct. App. 2014). “1 We hold that (1) the plain meaning of the relevant policy provisions entitles Ainsworth to income continuation benefits under the circumstances here, (2) Progressive unreasonably denied coverage and payment of benefits under the Insurance Fair Conduct Act (IFCA), RCW…”
Schreib v. Am. Fam. Mut. Ins., 129 F. Supp. 3d 1129 (W.D. Wash. 2015). “Schreib informed American Family that she would pursue claims under Washington’s Insurance Fair Conduct Act (“IFCA”), RCW 48.30.015. (Davis Deck ¶ 25, Ex. 15.) In December, 2012, pursuant to her policy, Ms.”
MKB Constructors v. Am. Zurich Ins., 49 F. Supp. 3d 814 (W.D. Wash. 2014). “) Fourth, MKB asks the court to rule on summary judgment that the fortuity doctrine is inapplicable. (Id. at 19-23.) Finally, MKB asks the court to rule as a matter of law that it has met the statutory preconditions for bringing a claim under Washington’s Insurance Fair Conduct…”
Trinity Universal Ins. v. Ohio Cas. Ins., 312 P.3d 976 (Wash. Ct. App. 2013). “RCW 48.30.015(1); RCW 19.86.090. Because Trinity’s action against Ohio was well within the superior court’s subject matter jurisdiction, all other defects or errors go to something other than subject matter jurisdiction.”
Workland & Witherspoon, PLLC v. Evanston Ins., 141 F. Supp. 3d 1148 (E.D. Wash. 2015). “Relevant to this order, Plaintiffs allege in Count V of their complaint a violation of the Washington State Insurance Fair Conduct Act (“IFCA”) under RCW 48.30.015. Id. at 7. Specifically, Plaintiffs allege that “[t]he acts or omissions alleged herein constitute an unreasonable…”
MKB Constructors v. Am. Zurich Ins., 83 F. Supp. 3d 1078 (W.D. Wash. 2015). “BACKGROUND The court conducted a jury trial from October 20, 2014, to October 24, 2014, on MKB’s claims against American Zurich for breach of contract, violation of the Insurance Fair Conduct Act (“IFCA”), RCW 48.30.015, and breach of the covenant of good faith and fair dealing.”
Seaway Props., LLC v. Fireman's Fund Ins., 16 F. Supp. 3d 1240 (W.D. Wash. 2014). “RCW § 48.30.015; § 48.30.015(5) (enumerating a host of insurance regulations).”
Nw. Mut. Life Ins. v. Koch, 771 F. Supp. 2d 1253 (W.D. Wash. 2009). “Defendant counterclaimed that, among other things, Plaintiff violated the Washington Insurance Fair Conduct Act (“IFCA”), RCW 48.30.015. Dkt. 6 ¶¶ 43-45. On August 18, 2009, Defendant filed a Motion for Trial by Jury on the Issue of Punitive Damages.”
Sarah Gosney, Res/cross-apps. v. Fireman's Fund Ins. Co., Apps/cross-res., 419 P.3d 447 (Wash. Ct. App. 2018). “2d 731 (1995). The CPA and IFCA both permit an award of attorney fees and costs to the prevailing party.”
Pendergrast v. Matichuk, 379 P.3d 96 (Wash. 2016). “030 (timber trespass statute), with RCW 48.30.015(2) (providing for treble damages under the Insurance Fair Conduct Act limited to actual damages), and RCW 19.”
— Wash. Rev. Code § 48.30.015(1) — 104 cases
Perez-Crisantos v. State Farm Fire & Cas. Co., 389 P.3d 476 (Wash. 2017). “¶1 In 2007, the legislature passed, and the voters of this state ratified, the Insurance Fair Conduct Act (IFCA), RCW 48.30.015. IFCA gives insureds a new cause of action against insurers who unreasonably deny coverage or benefits.”
Trinity Universal Ins. v. Ohio Cas. Ins., 312 P.3d 976 (Wash. Ct. App. 2013). “RCW 48.30.015(1); RCW 19.86.090. Because Trinity’s action against Ohio was well within the superior court’s subject matter jurisdiction, all other defects or errors go to something other than subject matter jurisdiction.”
Langley v. Geico Gen. Ins., 89 F. Supp. 3d 1083 (E.D. Wash. 2015). “The parties dispute what causes of action are available under the IFCA, codified at RCW 48.30.015. To determine what causes of action are available, the Court must turn to any controlling Washington Supreme Court precedent interpreting the applicable statute.”
Schreib v. Am. Fam. Mut. Ins., 129 F. Supp. 3d 1129 (W.D. Wash. 2015). “Schreib informed American Family that she would pursue claims under Washington’s Insurance Fair Conduct Act (“IFCA”), RCW 48.30.015. (Davis Deck ¶ 25, Ex. 15.) In December, 2012, pursuant to her policy, Ms.”
Workland & Witherspoon, PLLC v. Evanston Ins., 141 F. Supp. 3d 1148 (E.D. Wash. 2015). “Relevant to this order, Plaintiffs allege in Count V of their complaint a violation of the Washington State Insurance Fair Conduct Act (“IFCA”) under RCW 48.30.015. Id. at 7. Specifically, Plaintiffs allege that “[t]he acts or omissions alleged herein constitute an unreasonable…”
— Wash. Rev. Code § 48.30.015(2) — 45 cases
Ainsworth v. Progressive Cas. Ins., 322 P.3d 6 (Wash. Ct. App. 2014). “1 We hold that (1) the plain meaning of the relevant policy provisions entitles Ainsworth to income continuation benefits under the circumstances here, (2) Progressive unreasonably denied coverage and payment of benefits under the Insurance Fair Conduct Act (IFCA), RCW…”
Perez-Crisantos v. State Farm Fire & Cas. Co., 389 P.3d 476 (Wash. 2017). “¶1 In 2007, the legislature passed, and the voters of this state ratified, the Insurance Fair Conduct Act (IFCA), RCW 48.30.015. IFCA gives insureds a new cause of action against insurers who unreasonably deny coverage or benefits.”
Langley v. Geico Gen. Ins., 89 F. Supp. 3d 1083 (E.D. Wash. 2015). “The parties dispute what causes of action are available under the IFCA, codified at RCW 48.30.015. To determine what causes of action are available, the Court must turn to any controlling Washington Supreme Court precedent interpreting the applicable statute.”
Pendergrast v. Matichuk, 379 P.3d 96 (Wash. 2016). “030 (timber trespass statute), with RCW 48.30.015(2) (providing for treble damages under the Insurance Fair Conduct Act limited to actual damages), and RCW 19.”
Nw. Mut. Life Ins. v. Koch, 771 F. Supp. 2d 1253 (W.D. Wash. 2009). “Defendant counterclaimed that, among other things, Plaintiff violated the Washington Insurance Fair Conduct Act (“IFCA”), RCW 48.30.015. Dkt. 6 ¶¶ 43-45. On August 18, 2009, Defendant filed a Motion for Trial by Jury on the Issue of Punitive Damages.”
— Wash. Rev. Code § 48.30.015(3) — 24 cases
MKB Constructors v. Am. Zurich Ins., 83 F. Supp. 3d 1078 (W.D. Wash. 2015). “BACKGROUND The court conducted a jury trial from October 20, 2014, to October 24, 2014, on MKB’s claims against American Zurich for breach of contract, violation of the Insurance Fair Conduct Act (“IFCA”), RCW 48.30.015, and breach of the covenant of good faith and fair dealing.”
Perez-Crisantos v. State Farm Fire & Cas. Co., 389 P.3d 476 (Wash. 2017). “¶1 In 2007, the legislature passed, and the voters of this state ratified, the Insurance Fair Conduct Act (IFCA), RCW 48.30.015. IFCA gives insureds a new cause of action against insurers who unreasonably deny coverage or benefits.”
Sarah Gosney, Res/cross-apps. v. Fireman's Fund Ins. Co., Apps/cross-res., 419 P.3d 447 (Wash. Ct. App. 2018). “2d 731 (1995). The CPA and IFCA both permit an award of attorney fees and costs to the prevailing party.”
Ainsworth v. Progressive Cas. Ins., 322 P.3d 6 (Wash. Ct. App. 2014). “1 We hold that (1) the plain meaning of the relevant policy provisions entitles Ainsworth to income continuation benefits under the circumstances here, (2) Progressive unreasonably denied coverage and payment of benefits under the Insurance Fair Conduct Act (IFCA), RCW…”
Mut. Of Enumclaw, App./cross-res v. Myong Suk Day, Res/cross-appellant, 393 P.3d 786 (Wash. Ct. App. 2017).
— Wash. Rev. Code § 48.30.015(4) — 10 cases
Trinity Universal Ins. v. Ohio Cas. Ins., 312 P.3d 976 (Wash. Ct. App. 2013). “RCW 48.30.015(1); RCW 19.86.090. Because Trinity’s action against Ohio was well within the superior court’s subject matter jurisdiction, all other defects or errors go to something other than subject matter jurisdiction.”
Workland & Witherspoon, PLLC v. Evanston Ins., 141 F. Supp. 3d 1148 (E.D. Wash. 2015). “Relevant to this order, Plaintiffs allege in Count V of their complaint a violation of the Washington State Insurance Fair Conduct Act (“IFCA”) under RCW 48.30.015. Id. at 7. Specifically, Plaintiffs allege that “[t]he acts or omissions alleged herein constitute an unreasonable…”
Navigators Specialty Ins. v. Christensen Inc., 140 F. Supp. 3d 1097 (W.D. Wash. 2015).
Hartford Fire Ins. v. Leahy, 774 F. Supp. 2d 1104 (W.D. Wash. 2011).
John Webb & Krista Webb v. Usaa Cas. Ins. Co. (Wash. Ct. App. 2020).
— Wash. Rev. Code § 48.30.015(5) — 21 cases
Perez-Crisantos v. State Farm Fire & Cas. Co., 389 P.3d 476 (Wash. 2017). “¶1 In 2007, the legislature passed, and the voters of this state ratified, the Insurance Fair Conduct Act (IFCA), RCW 48.30.015. IFCA gives insureds a new cause of action against insurers who unreasonably deny coverage or benefits.”
Langley v. Geico Gen. Ins., 89 F. Supp. 3d 1083 (E.D. Wash. 2015). “The parties dispute what causes of action are available under the IFCA, codified at RCW 48.30.015. To determine what causes of action are available, the Court must turn to any controlling Washington Supreme Court precedent interpreting the applicable statute.”
Workland & Witherspoon, PLLC v. Evanston Ins., 141 F. Supp. 3d 1148 (E.D. Wash. 2015). “Relevant to this order, Plaintiffs allege in Count V of their complaint a violation of the Washington State Insurance Fair Conduct Act (“IFCA”) under RCW 48.30.015. Id. at 7. Specifically, Plaintiffs allege that “[t]he acts or omissions alleged herein constitute an unreasonable…”
Hell Yeah Cycles v. Ohio Sec. Ins., 16 F. Supp. 3d 1224 (E.D. Wash. 2014).
Seaway Props., LLC v. Fireman's Fund Ins., 16 F. Supp. 3d 1240 (W.D. Wash. 2014). “RCW § 48.30.015; § 48.30.015(5) (enumerating a host of insurance regulations).”
— Wash. Rev. Code § 48.30.015(5)(a) — 1 case
Fin. Pac. Leasing Inc v. RVI Am. Ins. Co (W.D. Wash. 2025).
— Wash. Rev. Code § 48.30.015(6) — 3 cases
Perez-Crisantos v. State Farm Fire & Cas. Co., 389 P.3d 476 (Wash. 2017). “¶1 In 2007, the legislature passed, and the voters of this state ratified, the Insurance Fair Conduct Act (IFCA), RCW 48.30.015. IFCA gives insureds a new cause of action against insurers who unreasonably deny coverage or benefits.”
Perez-Crisantos v. State Farm Fire & Cas. Co. (Wash. 2017).
Perez-Crisantos v. State Farm Fire & Cas. Co. (Wash. 2017).
— Wash. Rev. Code § 48.30.015(8) — 10 cases
Schreib v. Am. Fam. Mut. Ins., 304 F.R.D. 282 (W.D. Wash. 2014).
Cohodas v. The Cont'l Ins. Co. (CNA) (W.D. Wash. 2024).
Jason Gates & Amanda Gates, V. Homesite Ins. Co. (Wash. Ct. App. 2023).
Lyons v. USAA Cas. Ins. Co. (W.D. Wash. 2022).
Gochev v. First Am. Prop. & Cas. Ins. Co. (W.D. Wash. 2024).
— Wash. Rev. Code § 48.30.015(8)(a) — 25 cases
MKB Constructors v. Am. Zurich Ins., 49 F. Supp. 3d 814 (W.D. Wash. 2014). “) Fourth, MKB asks the court to rule on summary judgment that the fortuity doctrine is inapplicable. (Id. at 19-23.) Finally, MKB asks the court to rule as a matter of law that it has met the statutory preconditions for bringing a claim under Washington’s Insurance Fair Conduct…”
Jason Gates & Amanda Gates, V. Homesite Ins. Co. (Wash. Ct. App. 2023).
Washington Cities Ins. Auth. v. Ironshore Indem. Inc (W.D. Wash. 2020).
McDermed v. Safeco Ins. Co. of Am. (W.D. Wash. 2023).
Gochev v. First Am. Prop. & Cas. Ins. Co. (W.D. Wash. 2024).
— Wash. Rev. Code § 48.30.015(8)(b) — 6 cases
Gochev v. First Am. Prop. & Cas. Ins. Co. (W.D. Wash. 2024).
Jane Labeaume v. First Nat'l Ins. Co. of Am. (Wash. Ct. App. 2026).
Jason Gates & Amanda Gates, V. Homesite Ins. Co. (Wash. Ct. App. 2023).
Young v. Safeco Ins. Co. of Am. (W.D. Wash. 2022).
Gochev v. First Am. Prop. & Cas. Ins. Co. (W.D. Wash. 2023).
— Wash. Rev. Code § 48.30.015(8)(c) — 1 case
Tres Albatross, LLC v. Ohio Sec. Ins. Co. (W.D. Wash. 2025).
— Wash. Rev. Code § 48.30.015(8)(d) — 3 cases
Mayuga v. Sentinel Ins. Co. LTD (E.D. Wash. 2019).
Segar v. Allstate Fire & Cas. Ins. Co. (W.D. Wash. 2022).
Larson (W.D. Wash. 2025).
— Wash. Rev. Code § 48.30.015(l) — 1 case
Schreib v. Am. Fam. Mut. Ins., 129 F. Supp. 3d 1129 (W.D. Wash. 2015). “Schreib informed American Family that she would pursue claims under Washington’s Insurance Fair Conduct Act (“IFCA”), RCW 48.30.015. (Davis Deck ¶ 25, Ex. 15.) In December, 2012, pursuant to her policy, Ms.”
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