Wash. Rev. Code » Title 59 · Chapter 59.12
Revised Code of Washington

Wash. Rev. Code § 59.12.060 (2026)

Parties defendant

✓ current as of May 2026
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No person other than the tenant of the premises, and subtenant, if there be one, in the actual occupation of the premises when the complaint is filed, need be made parties defendant in any proceeding under this chapter, nor shall any proceeding abate, nor the plaintiff be nonsuited, for the nonjoinder of any person who might have been made party defendant; but when it appears that any of the parties served with process, or appearing in the proceeding, are guilty of the offense charged, judgment must be rendered against him or her. In case a person has become a subtenant of the premises in controversy after the service of any notice in this chapter provided for, the fact that such notice was not served on such subtenant shall constitute no defense to the action. All persons who enter the premises under the tenant, after the commencement of the action hereunder, shall be bound by the judgment the same as if they had been made parties to the action.
[ 2010 c 8 s 19008; 1891 c 96 s 7; RRS s 816. Prior: 1890 p 75 s 6.]
Notes of Decisions
Cited in 11 cases (7 in the last 5 years), 1983–2026 · leading case: Laffranchi v. Lim, 190 P.3d 97 (Wash. Ct. App. 2008).
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Laffranchi v. Lim, 190 P.3d 97 (Wash. Ct. App. 2008). · cites it 3× “[7] DeVore argues that the court never acquired subject matter jurisdiction because Laffranchi failed to join as a party a tenant in possession as required by RCW 59.12.060. [8] Laffranchi responds that DeVore failed to raise this issue in the trial court and that, as a…”
Laffranchi v. Lim, 146 Wash. App. 376 (Wash. Ct. App. 2008). · cites it 3× “7 DeVore argues that the *383 court never acquired subject matter jurisdiction because Laffranchi failed to join as a party a tenant in possession as required by RCW 59.12.060. 8 Laffranchi responds that DeVore failed to raise this issue in the trial court and that, as a…”
Hous. Auth. v. Knight, 563 P.3d 1058 (Wash. 2025). “365; RCW 59.12.060, .080. To evict a tenant, a landlord may apply for a writ of restitution.”
Daniels v. Ward, 669 P.2d 495 (Wash. Ct. App. 1983). · cites it 3× “They argue that under RCW 59.12.060 Lafitte's Ltd. or 13 Coins was a necessary defendant to an unlawful detainer action.”
Allen Watkins & Janis Clark, Appellant's V. Esa Mgmt. (Wash. Ct. App. 2024). · cites it 4× “85225-6-I new tenant after remand, that new tenant is a necessary party under RCW 59.12.060 and must be joined if they assert a right to possess the property.”
Allen Watkins & Janis Clark, Appellant's V. Esa Mgmt. (Wash. Ct. App. 2024). · cites it 4× “85225-6-I necessary party under RCW 59.12.060 and must be joined if they assert a right to possess the property.”
Arthur Skinner, Res/cross-app V. Incity Props. Holdings Inc, App/cross-res (Wash. Ct. App. 2025). · cites it 4× “Under RCW 59.12.060, anyone who enters “under the tenant, after the commencement of the action .”
Patricia L. West v. Mark S. Ritts (Wash. Ct. App. 2021). · cites it 3× “Next, citing RCW 59.12.060, he argues the trial court had no authority to evict him because he was not in “actual occupation” of the property when the complaint was filed.”
Arthur Skinner, Res/cross-app V. Incity Props. Holdings Inc, App/cross-res (Wash. Ct. App. 2025). · cites it 2× “Under RCW 59.12.060, anyone who enters “under the tenant, after the commencement of the action .”
Guy Way & Zenaida Way v. John Choquer (Wash. Ct. App. 2016). “RCW 59.12.060 states that “[n]o person other than the tenant of the premises .”
Esterra Commons Venture, Llc, V. Justin Norton (Wash. Ct. App. 2026). “365; RCW 59.12.060, .080). The landlord may then request a writ of restitution and note the request for a show cause hearing to request possession of the property on 5 87320-2-I/6 an expedited basis.”
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