Revised Code of Washington
Wash. Rev. Code § 64.40.040 (2026)
Remedies cumulative
✓ current as of May 2026
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The remedies provided by this chapter are in addition to any other remedies provided by law.
[ 1982 c 232 s 4.]
Notes of Decisions
Cited in 7
cases, 1993–2007 · leading case: Hayes v. City of Seattle, 131 Wash. 2d 706 (Wash. 1997).
Hayes v. City of Seattle, 131 Wash. 2d 706 (Wash. 1997). “Instead, the majority disregards 100 years of claim preclusion law in Washington and ignores crystal clear language in RCW 64.40.040 to avoid reaching the fundamental land use issues.”
Hayes v. City of Seattle, 934 P.2d 1179 (Wash. 1997). “Instead, the majority disregards 100 years of claim preclusion law in Washington and ignores crystal clear language in RCW 64.40.040 to avoid reaching the fundamental land use issues.”
Westmark Dev. Corp. v. City of Burien, 140 Wash. App. 540 (Wash. Ct. App. 2007). “40 RCW, however, does not preclude Westmark from recovering damages under a common-law tort theory because the statute itself provides that it is “in addition to any other remedies provided by law,” RCW 64.40.040, and Washington precedent allows common-law tort claims in…”
Westmark Dev. Corp. v. City of Burien, 166 P.3d 813 (Wash. Ct. App. 2007). “40 RCW, however, does not preclude Westmark from recovering damages under a common-law tort theory because the statute itself provides that it is "in addition to any other remedies provided by law," RCW 64.40.040, and Washington precedent allows common-law tort claims in…”
Saldin Sec., Inc. v. Snohomish Cnty., 134 Wash. 2d 288 (Wash. 1998). “§ 1983 and RCW 64.40.040. Petitioners, however, failed to provide *298 this court with any analysis in the argument section of the petition for review.”
Saldin Sec., Inc. v. Snohomish Cnty., 949 P.2d 370 (Wash. 1998). “§ 1983 and RCW 64.40.040. Petitioners, however, failed to provide this court with any analysis in the argument section of the petition for review.”
Wilson v. City of Seattle, 863 P.2d 1336 (Wash. 1993). “020 is not merely a codification of preexisting common law tort remedies, but is a new cause of action not previously available.”
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