Wash. Rev. Code » Title 64 · Chapter 64.12
Revised Code of Washington

Wash. Rev. Code § 64.12.020 (2026)

Waste by guardian or tenant, action for

✓ current as of May 2026
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If a guardian, tenant in severalty or in common, for life or for years, or by sufferance, or at will, or a subtenant, of real property commit waste thereon, any person injured thereby may maintain an action at law for damages therefor against such guardian or tenant or subtenant; in which action, if the plaintiff prevails, there shall be judgment for treble damages, or for fifty dollars, whichever is greater, and the court, in addition may decree forfeiture of the estate of the party committing or permitting the waste, and of eviction from the property. The judgment, in any event, shall include as part of the costs of the prevailing party, a reasonable attorney's fee to be fixed by the court. But judgment of forfeiture and eviction shall only be given in favor of the person entitled to the reversion against the tenant in possession, when the injury to the estate in reversion is determined in the action to be equal to the value of the tenant's estate or unexpired term, or to have been done or suffered in malice.
[ 1943 c 22 s 1; Code 1881 s 601; 1877 p 125 s 606; 1869 p 143 s 555; 1854 p 206 s 403; Rem. Supp. 1943 s 938.]
Notes of Decisions
Cited in 16 cases (3 in the last 5 years), 1969–2024 · leading case: Fisher Props., Inc. v. Arden-Mayfair, Inc., 726 P.2d 8 (Wash. 1986).
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Fisher Props., Inc. v. Arden-Mayfair, Inc., 726 P.2d 8 (Wash. 1986). · cites it 18× “On February 1, 1983, Fisher notified Arden that at the commencement of trial, it would expand its prayer for relief to include treble damages and attorney fees pursuant to RCW 64.12.020 for the commission of waste.”
Eastwood v. Horse Harbor Found., Inc., 241 P.3d 1256 (Wash. 2010). · cites it 10× “They also argued that Horse Harbor's corporate form protected Warren and the Dalings from being held individually liable.”
Eastwood v. Horse Harbor Found., Inc., 170 Wash. 2d 380 (Wash. 2010). · cites it 10× “They also argued that Horse Harbor’s corporate form protected Warren and the Dalings from being held individually liable.”
Seattle-First Nat'l Bank v. Brommers, 570 P.2d 1035 (Wash. 1977). · cites it 6× “Pursuant to RCW 64.12.020, 4 the court trebled this figure and assessed damages against Mrs.”
JDFJ CORP. v. Int'l Raceway, Inc., 970 P.2d 343 (Wash. Ct. App. 1999). “In a four-day bench trial, JDFJ sought $325,000, which it asked to be trebled for timber waste under RCW 64.12.020 or for timber trespass under RCW 64.”
Watkins v. Restorative Care Ctr., Inc., 831 P.2d 1085 (Wash. Ct. App. 1992). “Similarly, under RCW 64.12.020, tenants of real property are prohibited from committing waste of the lessor's property.”
Dorsey v. Speelman, 459 P.2d 416 (Wash. Ct. App. 1969). · cites it 2× “For a number of the items, plaintiffs sought treble damages under RCW 64.12.020, which provides in part: If a .”
Kane v. Timm, 527 P.2d 480 (Wash. Ct. App. 1974). · cites it 2× “” The trial court found that all of the items taken, except the electric baseboard heaters, were fixtures and thus the plaintiff was entitled to their replacement value.”
Justin Bloch v. Kathleen Bloch (Wash. Ct. App. 2020). · cites it 19× “2 Prior to their marriage, Justin purchased his home at 1555 Broadway East in Seattle.”
Tuthill v. Palermo, 545 P.2d 588 (Wash. Ct. App. 1976). · cites it 2× “28 pursuant to RCW 64.12.020 (waste) and RCW 64.12.030 (trespass).”
Est. Of Doris Mathews (Wash. Ct. App. 2017). · cites it 2× “4 In a fiduciary relationship, one party “‘occupies such a relation to the other party as to justify the latter in expecting that his interests will be cared for.”
Patrisha Lussier v. Nathan Sprickerhoff, Clare Juico (Wash. Ct. App. 2019). “In Suit II, Lussier asserted claims of breach of oral contract to maintain the property, waste, negligent injury to property, intentional injury to property, and attorney fees pursuant to RCW 64.”
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