Revised Code of Washington

Wash. Rev. Code § 64.40.030 (2026)

✓ current as of May 2026
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Any action to assert claims under the provisions of this chapter shall be commenced only within thirty days after all administrative remedies have been exhausted.
[ 1982 c 232 s 3.]
Notes of Decisions
Cited in 31 cases (3 in the last 5 years), 1985–2025 · leading case: Callfas v. Dep't of Constr. & Land Use, 120 P.3d 110 (Wash. Ct. App. 2005).
Callfas v. Dep't of Constr. & Land Use, 120 P.3d 110 (Wash. Ct. App. 2005). · cites it 14× “The City then filed a motion for summary judgment claiming that the Callfases’ original suit was barred by the limitations period in RCW 64.40.030. The trial court agreed and dismissed the action.”
City of Seattle v. Blume, 134 Wash. 2d 243 (Wash. 1997). · cites it 7× “In an unpublished opinion, the Court of Appeals affirmed, finding that both claims were barred by the 30-day statute of limitations period provided in RCW 64.40.030. The Blumes filed a motion for reconsideration arguing their claim for tortious interference with a business…”
City of Seattle v. Blume, 947 P.2d 223 (Wash. 1997). · cites it 7× “In an unpublished opinion, the Court of Appeals affirmed, finding that both claims were barred by the 30-day statute of limitations period provided in RCW 64.40.030. The Blumes filed a motion for reconsideration arguing their claim for tortious interference with a business…”
Hayes v. City of Seattle, 131 Wash. 2d 706 (Wash. 1997). · cites it 4× “020 was barred by the applicable statute of limitations, RCW 64.40.030? 5 In concluding that Hayes’s claim under RCW 64.”
Hayes v. City of Seattle, 934 P.2d 1179 (Wash. 1997). · cites it 4× “020 was barred by the applicable statute of limitations, RCW 64.40.030? [5] In concluding that Hayes's claim under RCW 64.”
Smoke v. City of Seattle, 937 P.2d 186 (Wash. 1997). · cites it 6× “Plaintiffs received a judgment for the stipulated damages plus attorney fees. The trial court dismissed Plaintiffs' claims for a 42 U.”
Smoke v. City of Seattle, 902 P.2d 678 (Wash. Ct. App. 1995). · cites it 10× “RCW 64.40.030. The statute plainly requires actions to be commenced "only .”
Smoke v. City of Seattle, 937 P.2d 186 (Wash. 1997). · cites it 5× “Although we conclude RCW 64.40.030 requires the exhaustion of administrative remedies, we hold an interpretation does not constitute an adequate administrative remedy for a Type I MUP denial.”
Kenneth & Kelly Emerson, Apps. v. Island Cnty., Resp., 371 P.3d 93 (Wash. Ct. App. 2016). · cites it 3× “” RCW 64.40.030. ¶25 The county’s motion for summary judgment argued that the Emersons failed to exhaust their administrative remedies.”
Westmark Dev. Corp. v. City of Burien, 140 Wash. App. 540 (Wash. Ct. App. 2007). · cites it 3× “” RCW 64.40.030. *549 ¶13 The plain language of chapter 64.”
Westmark Dev. Corp. v. City of Burien, 166 P.3d 813 (Wash. Ct. App. 2007). · cites it 3× “" RCW 64.40.030. ¶ 13 The plain language of chapter 64.”
Birnbaum v. Pierce Cnty., 274 P.3d 1070 (Wash. Ct. App. 2012). · cites it 3× “” RCW 64.40.030. “Damages” means reasonable expenses and losses, other than speculative losses and profits, incurred between the time a cause of action arises and the time a holder of an interest in real property is granted relief.”
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