Wash. Rev. Code » Title 7 · Chapter 7.70
Revised Code of Washington

Wash. Rev. Code § 7.70.110 (2026)

✓ current as of May 2026
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The making of a written, good faith request for mediation of a dispute related to damages for injury occurring as a result of health care prior to filing a cause of action under this chapter shall toll the statute of limitations provided in RCW 4.16.350 for one year.
[ 1996 c 270 s 1; 1993 c 492 s 420.]

Notes:

Findings—Intent—1993 c 492: See notes following RCW 43.20.050.
Short title—Savings—Reservation of legislative power—Effective dates—1993 c 492: See RCW 43.72.910 through 43.72.915.
Notes of Decisions
Cited in 30 cases (9 in the last 5 years), 2008–2026 · leading case: Fast v. Kennewick Pub. Hosp. Dist., 384 P.3d 232 (Wash. 2016).
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Fast v. Kennewick Pub. Hosp. Dist., 384 P.3d 232 (Wash. 2016). · cites it 9× “RCW 7.70.110. ¶2 The general torts catchall statute of limitations is also three years.”
Unruh v. Cacchiotti, 257 P.3d 631 (Wash. 2011). · cites it 20× “A few days later, on January 12, Unruh’s counsel sent a letter to Cacchiotti’s insurance representative requesting mediation under RCW 7.70.110. The insurance representative responded by letter, stating, “You have requested mediation based on RCW 7.”
Reyes v. Yakima Health Dist., 419 P.3d 819 (Wash. 2018). “During the pendency of the appeal, this court reversed Fast and held that the one-year tolling provision in RCW 7.70.110 applies to such a claim. Fast v.”
Breuer v. Douglas D. Presta, Dpm, 200 P.3d 724 (Wash. Ct. App. 2009). · cites it 4× “Presta amount to a "request" for mediation and therefore the statute of limitations did not run by operation of RCW 7.70.110 (good faith request for mediation tolls the statute of limitations).”
Breuer v. Presta, 148 Wash. App. 470 (Wash. Ct. App. 2009). · cites it 4× “Presta amount to a “request” for mediation and therefore the statute of limitations did not run by operation of RCW 7.70.110 (good faith request for mediation tolls the statute of limitations).”
Fast v. Kennewick Pub. Hosp. Dist., 354 P.3d 858 (Wash. Ct. App. 2015). · cites it 2× “RCW 7.70.110. ¶8 The defendants expressed no interest in mediating, and eventually, on July 18,2012, the Fasts commenced legal action against Dr.”
Cortez-kloehn v. Morrison, 252 P.3d 909 (Wash. Ct. App. 2011). · cites it 7× “350 is denominated as the statute of limitations for bringing a medical malpractice action, *912 and that is the sole subject matter of the statute.”
Young Soo Kim v. Choong-Hyun Lee, 300 P.3d 431 (Wash. Ct. App. 2013). “Because Kim sent Lee a mediation request on March 18, 2010, the statute of limitations was tolled for one year under RCW 7.70.110 if the statute of limitations commenced, as Kim contends, on March 29,2007.”
Morris v. Swedish Health Servs., 148 Wash. App. 771 (Wash. Ct. App. 2009). · cites it 2× “4 The effect of that letter was to toll the statute of limitations for one year under RCW 7.70.110: The making of a written, good faith request for mediation of a dispute related to damages for injury occurring as a result of health care prior to filing a cause of action under…”
David M. Fraley, V. Commonspirit Health (Wash. Ct. App. 2023). · cites it 36× “Blair argue the trial court erred in concluding that Fraley’s mediation letter was sufficient to toll the statute of limitations for one year under RCW 7.70.110. On the facts of this case, we hold that the trial court did not err in denying Proliance and Dr.”
Nancy Fechner v. Scott Volyn dba Volyn Law Firm, 418 P.3d 120 (Wash. Ct. App. 2018). · cites it 4× “Dietzman would have expired in May 2012, unless a request for mediation under RCW 7.70.110 was made prior to that date.”
Morris v. Swedish Health Servs., 200 P.3d 261 (Wash. Ct. App. 2009). · cites it 3× “100, and a good faith request for mediation pursuant to RCW 7.70.110. On September 13, 2007, without any attempts at mediation, Morris refiled the lawsuit.”
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