Wash. Rev. Code » Title 60 · Chapter 60.04
Revised Code of Washington

Wash. Rev. Code § 60.04.181 (2026)

✓ current as of May 2026
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(1) In every case in which different construction liens are claimed against the same property, the court shall declare the rank of such lien or class of liens, which liens shall be in the following order:
(a) Liens for the performance of labor;
(b) Liens for contributions owed to employee benefit plans;
(c) Liens for furnishing material, supplies, or equipment;
(d) Liens for subcontractors, including but not limited to their labor and materials; and
(e) Liens for prime contractors, or for professional services.
(2) The proceeds of the sale of property must be applied to each lien or class of liens in order of its rank and, in an action brought to foreclose a lien, pro rata among each claimant in each separate priority class. A personal judgment may be rendered against any party personally liable for any debt for which the lien is claimed. If the lien is established, the judgment shall provide for the enforcement thereof upon the property liable as in the case of foreclosure of judgment liens. The amount realized by such enforcement of the lien shall be credited upon the proper personal judgment. The deficiency, if any, remaining unsatisfied, shall stand as a personal judgment, and may be collected by execution against any party liable therefor.
(3) The court may allow the prevailing party in the action, whether plaintiff or defendant, as part of the costs of the action, the moneys paid for recording the claim of lien, costs of title report, bond costs, and attorneys' fees and necessary expenses incurred by the attorney in the superior court, court of appeals, supreme court, or arbitration, as the court or arbitrator deems reasonable. Such costs shall have the priority of the class of lien to which they are related, as established by subsection (1) of this section.
(4) Real property against which a lien under this chapter is enforced may be ordered sold by the court and the proceeds deposited into the registry of the clerk of the court, pending further determination respecting distribution of the proceeds of the sale.
[ 1992 c 126 s 12; 1991 c 281 s 18.]
Notes of Decisions
Cited in 63 cases (15 in the last 5 years), 1993–2025 · leading case: Est. of Haselwood v. Bremerton Ice Arena, Inc., 210 P.3d 308 (Wash. 2009).
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Est. of Haselwood v. Bremerton Ice Arena, Inc., 210 P.3d 308 (Wash. 2009). · cites it 3× “In an action in which different construction liens are claimed against the same property, RCW 60.04.181(3) provides that “[t]he court may allow the prevailing party in the action, whether plaintiff or defendant, as part of the costs of the action, .”
Scott's Excavating Vancouver, LLC v. Winlock Props., LLC, 308 P.3d 791 (Wash. Ct. App. 2013). · cites it 3× “We also award attorney fees and costs to G&O as the prevailing party under RCW 60.04.181(3). *339 FACTS ¶3 In February 2005, G&O sent a proposal to Winlock for engineering and surveying services on Winlock’s new housing and commercial development called the Grand Prairie…”
Blue Diamond Grp., Inc. v. KB Seattle 1, Inc., 266 P.3d 881 (Wash. Ct. App. 2011). · cites it 4× “¶31 Blue Diamond next argues that the trial court erred in awarding attorney fees under RCW 60.04.181 because that provision is inconsistent with RCW 60.”
CalPortland Co. v. LevelOne Concrete, LLC, 321 P.3d 1261 (Wash. Ct. App. 2014). · cites it 6× “Ferguson and Travelers also requested costs and attorney fees under RCW 60.04.181. ¶6 The trial court granted the motion for summary judgment, setting forth the reasons in a memorandum decision.”
Cesar Hernandez v. Edmonds Memory Care, Llc, 450 P.3d 622 (Wash. Ct. App. 2019). · cites it 15× “The superior court awarded the laborers $7,000 in attorney fees, relying on RCW 60.04.181;1 it found that the laborers “are the prevailing parties in an action because they filed their complaint in the instant action and recovered 100% of the lien wages sought in their complaint.”
Olson Eng'g, Inc. v. KeyBank Nat'l Ass'n, 286 P.3d 390 (Wash. Ct. App. 2012). · cites it 7× “161 “create a conflict” with RCW 60.04.181, which requires courts to rank construction liens.”
Shelcon Constr. Grp., LLC v. Haymond, 351 P.3d 895 (Wash. Ct. App. 2015). · cites it 3× “Shelcon is also entitled to reasonable attorney fees from Haymond under RCW 60.04.181(3), which provides that the prevailing party in an action to enforce a mechanic’s lien is entitled to attorney fees.”
Diversified Wood Recycling, Inc. v. Johnson, 251 P.3d 293 (Wash. Ct. App. 2011). · cites it 2× “171, nonjoinder of Kuleana would not require the trial court to dismiss the foreclosure action.”
Haselwood v. Bremerton Ice Arena, Inc., 155 P.3d 952 (Wash. Ct. App. 2007). · cites it 2× “RCW 4.84.010 allows the prevailing party in a civil action to recover costs and disbursements.”
Haselwood v. Bremerton Ice Arena, Inc., 137 Wash. App. 872 (Wash. Ct. App. 2007). · cites it 2× “010 allows the prevailing party in a civil action to recover costs and disbursements.”
Diversified Wood Recycling, Inc. v. Johnson, 161 Wash. App. 859 (Wash. Ct. App. 2011). · cites it 2× “They were not generated until two years later. We do not deem these materials necessary to reach a decision on the merits of the trial rulings at issue in this appeal.”
DBM Consulting Engineers, Inc. v. United States Fid. & Guar. Co., 142 Wash. App. 35 (Wash. Ct. App. 2007). · cites it 2× “1 and RCW 60.04.181. This statute permits the court to award reasonable attorney fees and costs to the prevailing party in an action to enforce a lien.”
Show all 63 citing cases →
— Wash. Rev. Code § 60.04.181(1) — 1 case
Olson Eng'g, Inc. v. KeyBank Nat'l Ass'n, 286 P.3d 390 (Wash. Ct. App. 2012). “161 “create a conflict” with RCW 60.04.181, which requires courts to rank construction liens.”
— Wash. Rev. Code § 60.04.181(1)(d) — 1 case
Skanska Usa Bldg. Inc., V. 1200 Howell Street, Llc (Wash. Ct. App. 2025).
— Wash. Rev. Code § 60.04.181(2) — 3 cases
CalPortland Co. v. LevelOne Concrete, LLC, 321 P.3d 1261 (Wash. Ct. App. 2014). “Ferguson and Travelers also requested costs and attorney fees under RCW 60.04.181. ¶6 The trial court granted the motion for summary judgment, setting forth the reasons in a memorandum decision.”
Olson Eng'g, Inc. v. KeyBank Nat'l Ass'n, 286 P.3d 390 (Wash. Ct. App. 2012). “161 “create a conflict” with RCW 60.04.181, which requires courts to rank construction liens.”
Stonewood Design, Inc. v. Heritage Homes, Inc., 269 P.3d 297 (Wash. Ct. App. 2011).
— Wash. Rev. Code § 60.04.181(3) — 52 cases
Est. of Haselwood v. Bremerton Ice Arena, Inc., 210 P.3d 308 (Wash. 2009). “In an action in which different construction liens are claimed against the same property, RCW 60.04.181(3) provides that “[t]he court may allow the prevailing party in the action, whether plaintiff or defendant, as part of the costs of the action, .”
Scott's Excavating Vancouver, LLC v. Winlock Props., LLC, 308 P.3d 791 (Wash. Ct. App. 2013). “We also award attorney fees and costs to G&O as the prevailing party under RCW 60.04.181(3). *339 FACTS ¶3 In February 2005, G&O sent a proposal to Winlock for engineering and surveying services on Winlock’s new housing and commercial development called the Grand Prairie…”
Blue Diamond Grp., Inc. v. KB Seattle 1, Inc., 266 P.3d 881 (Wash. Ct. App. 2011). “¶31 Blue Diamond next argues that the trial court erred in awarding attorney fees under RCW 60.04.181 because that provision is inconsistent with RCW 60.”
Shelcon Constr. Grp., LLC v. Haymond, 351 P.3d 895 (Wash. Ct. App. 2015). “Shelcon is also entitled to reasonable attorney fees from Haymond under RCW 60.04.181(3), which provides that the prevailing party in an action to enforce a mechanic’s lien is entitled to attorney fees.”
Cesar Hernandez v. Edmonds Memory Care, Llc, 450 P.3d 622 (Wash. Ct. App. 2019). “The superior court awarded the laborers $7,000 in attorney fees, relying on RCW 60.04.181;1 it found that the laborers “are the prevailing parties in an action because they filed their complaint in the instant action and recovered 100% of the lien wages sought in their complaint.”
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