Revised Code of Washington
Wash. Rev. Code § 7.28.050 (2026)
✓ current as of May 2026
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That all actions brought for the recovery of any lands, tenements or hereditaments of which any person may be possessed by actual, open and notorious possession for seven successive years, having a connected title in law or equity deducible of record from this state or the United States, or from any public officer, or other person authorized by the laws of this state to sell such land for the nonpayment of taxes, or from any sheriff, marshal or other person authorized to sell such land on execution or under any order, judgment or decree of any court of record, shall be brought within seven years next after possession being taken as aforesaid, but when the possessor shall acquire title after taking such possession, the limitation shall begin to run from the time of acquiring title.
[ 1893 c 11 s 1; RRS s 786.]
Notes of Decisions
Cited in 13
cases, 1955–2016 · leading case: Gorman v. City of Woodinville, 283 P.3d 1082 (Wash. 2012).
Gorman v. City of Woodinville, 283 P.3d 1082 (Wash. 2012). “070, and RCW 7.28.050. In 1892, the first of these statutes was identified as an adverse possession statute.”
Harris v. Urell, 133 Wash. App. 130 (Wash. Ct. App. 2006). “Permissive use ¶32 The pivotal issue, then, is whether the Wattses’ use was “open and notorious” under RCW 7.28.050 when Mike Watts first asked for and obtained Harris’s permission to use the disputed property (after she had gained ownership by adverse possession).”
Harris v. Urell, 135 P.3d 530 (Wash. Ct. App. 2006). “Permissive use ¶ 32 The pivotal issue, then, is whether the Watts' use was "open and notorious" under *536 RCW 7.28.050 when Mike Watts first asked for and obtained Harris's permission to use the disputed property (after she had gained ownership by adverse possession).”
Northlake Marine Works, Inc. v. City of Seattle, 857 P.2d 283 (Wash. Ct. App. 1993). “The court alternatively held that the railroad had received title to lot 19 by adverse possession under the connected title statute, RCW 7.28.050. The trial court also dismissed claim 2, reasoning that the agreement was for a public purpose and was supported by consideration;…”
Beebe v. Swerda, 793 P.2d 442 (Wash. Ct. App. 1990). “Swerda cites RCW 7.28.050 in support of his argument that he possessed the easement in question adverse to Beebe under a claim of title, and thus the statute of limitations barred an action to quiet title.”
Kunkel v. Fisher, 23 P.3d 1128 (Wash. Ct. App. 2001). “020; RCW 7.28.050; RCW 7.28.070; RCW 7.28.085.”
Kunkel v. Fisher, 106 Wash. App. 599 (Wash. Ct. App. 2001). “020; RCW 7.28.050; RCW 7.28.070; RCW 7.28.085.”
Peters v. Skalman, 617 P.2d 448 (Wash. Ct. App. 1980). “The evidence shows that besides using the property to graze farm animals, John built a fence between the east and west parcels, moved a barn onto the land, and made arrangements to have water lines connected to the property. In addition, it is undisputed that he and Nickie paid…”
Houplin v. Stoen, 431 P.2d 998 (Wash. 1967). “Other statutory means of transfer of title to real property include inheritance (RCW 11.04.050); devise (RCW 11.”
Harkins v. Del Pozzi, 310 P.2d 532 (Wash. 1957). “The court determined that adverse possession had been established under RCW 7.28.050, 7.28.070, 7.28.080 [cf. Rem.”
Doyle v. Hicks, 897 P.2d 420 (Wash. Ct. App. 1995). “1 The Doyles apparently do not rely upon RCW 7.28.050 which vests title if possession is actual, open and notorious for a period of seven consecutive years with connected title deducible of record from the state or the United States.”
Mourik v. Adams, 287 P.2d 320 (Wash. 1955). “Respondent did not introduce any evidence in support of her pleaded defense under the provisions of RCW 7.28.050, which relates to adverse possession under connected title deducible of record from the state or Federal government or from a public officer.”
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