Revised Code of Washington
Wash. Rev. Code § 61.12.120 (2026)
Concurrent actions prohibited
✓ current as of May 2026
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The plaintiff shall not proceed to foreclose his or her mortgage while he or she is prosecuting any other action for the same debt or matter which is secured by the mortgage, or while he or she is seeking to obtain execution of any judgment in such other action; nor shall he or she prosecute any other action for the same matter while he or she is foreclosing his or her mortgage or prosecuting a judgment of foreclosure.
[ 2012 c 117 s 164; Code 1881 s 614; 1877 p 128 s 619; 1869 p 146 s 568; 1854 p 208 s 413; RRS s 1125.]
Notes of Decisions
Cited in 14
cases (1 in the last 5 years), 1972–2021 · leading case: Deutsche Bank Nat'l Trust Co. v. Valerie J. Slotke, 367 P.3d 600 (Wash. Ct. App. 2016).
Deutsche Bank Nat'l Trust Co. v. Valerie J. Slotke, 367 P.3d 600 (Wash. Ct. App. 2016). “45 ¶35 The plain words of RCW 61.12.120 are dispositive of this argument.”
Am. Fed. Sav. & Loan Ass'n of Tacoma v. McCaffrey, 728 P.2d 155 (Wash. 1986). “060 grants the trial court the authority to set an upset price either before or after the sale of the mortgaged property and to require that the price be credited against the judgment as a condition to confirmation of the sale.”
Farm Credit Bank v. Tucker, 813 P.2d 619 (Wash. Ct. App. 1991). “1 The Tuckers are not aided by their reliance upon RCW 61.12.120. That statute bars a plaintiff from foreclosing "while he is prosecuting any other action for the same debt or matter which is secured by the mortgage .”
Boeing Employees' Credit Union v. Burns, 272 P.3d 908 (Wash. Ct. App. 2012). “39 RCW 61.12.120 (“The plaintiff shall not proceed to foreclose his mortgage while he is prosecuting any other action for the same debt or matter which is secured by the mortgage .”
DeYoung v. Cenex Ltd., 1 P.3d 587 (Wash. Ct. App. 2000). “RCW 61.12.120; American Federal, 107 Wash.”
Royal Palm Corp. Ctr. Ass'n v. PNC Bank, NA, 89 So. 3d 923 (Fla. 4th DCA 2012). “§ 429 (consecutively); Utah Code § 78B-6-901 (one action); Wash. Rev.Code § 61.12.120 (consecutively); Wyo.”
Peoples Nat'l Bank v. Peterson, 514 P.2d 159 (Wash. 1973). “These motions were essentially predicated upon the contention that the bank was pursuing concurrent remedies in the foreclosure proceeding contrary to RCW 61.12.120. 5 The trial court granted these motions.”
U.S. Bank Nat'l Ass'n as Tr. of Holders of Adjustable Rate Mortg. Trust 2007-2 v. Ukpoma, 438 P.3d 141 (Wash. Ct. App. 2019). “These provisions are mirrored by a judicial foreclosure provision, RCW 61.12.120, which prohibits concurrent actions.”
Deere Credit, Inc. v. Cervantes Nurseries, LLC, 288 P.3d 409 (Wash. Ct. App. 2012). “The defendants objected to the state court proceedings and argued that they violated Washington’s single-action rule (RCW 61.12.120). We conclude that the state court proceedings did not duplicate the bankruptcy proceedings and do not therefore violate the single-action rule,…”
Peoples Nat'l Bank v. Peterson, 498 P.2d 884 (Wash. Ct. App. 1972). “These portions alleged that when defendants applied to plaintiff for a loan, it was represented in a financial statement that defendants owned certain farmlands; that the loan was approved based upon the representations contained in that statement; that after obtaining the loan…”
DeYoung v. Cenex Ltd., 100 Wash. App. 885 (Wash. Ct. App. 2000). “RCW 61.12.120; American Federal, 107 Wn.2d at 190 .”
Citimortgage Inc. v. Paul & Michelle Moseley (Wash. Ct. App. 2021). “Moseley also alleges that CitiMortgage and Cenlar are engaging in “concurrent actions” in violation of RCW 61.12.120 because CitiMortgage obtained an order of sale and then Cenlar “provided the Appellant a ‘loan workout’ program.”
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