Revised Code of Washington
Wash. Rev. Code § 74.34.110 (2026)
✓ current as of May 2026
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A vulnerable adult, or interested person on behalf of the vulnerable adult, may seek relief from abandonment, abuse, financial exploitation, or neglect, or the threat thereof, by filing a petition for a vulnerable adult protection order under chapter 7.105 RCW.
Notes:
Effective date—2022 c 268; 2021 c 215: See note following RCW 7.105.900.
Findings—Purpose—Severability—Conflict with federal requirements—1999 c 176: See notes following RCW 74.34.005.
Notes of Decisions
Cited in 25
cases (7 in the last 5 years), 2008–2024 · leading case: Knight v. Knight, 317 P.3d 1068 (Wash. Ct. App. 2014).
Knight v. Knight, 317 P.3d 1068 (Wash. Ct. App. 2014). “RCW 74.34.110. “A vulnerable adult, or interested person on behalf of the vulnerable adult, may [file] a petition for an order for protection in superior court.”
Endicott v. Saul, 142 Wash. App. 899 (Wash. Ct. App. 2008). “110(2) provides that [a] petition shall allege that the petitioner is a vulnerable adult and that the petitioner has been abandoned, abused, financially exploited, or neglected, or is threatened with abandonment, abuse, financial exploitation, or neglect by respondent.”
Raven v. Dep't of Soc. & Health Servs., 306 P.3d 920 (Wash. 2013). “DSHS may also seek a protective order against a guardian under RCW 74.34.110. We cite to the administrative record for the text of the standards because since the time of the hearing, the standards have been renumbered.”
Karanjah v. Dep't of Soc. & Health Servs., 199 Wash. App. 903 (Wash. Ct. App. 2017). “RCW 74.34.110. “ Abuse’ means the willful action or inaction that inflicts injury, unreasonable confinement, intimidation, or punishment on a vulnerable adult” and includes the “improper use of restraint against a vulnerable adult.”
Goldsmith v. Dep't of Soc. & Health Servs., 280 P.3d 1173 (Wash. Ct. App. 2012). “See RCW 74.34.110 (creating action for protection order in cases of abandonment, abuse, financial exploitation, or neglect of vulnerable adult).”
In re the Est. of Haviland, 301 P.3d 31 (Wash. 2013). “RCW 74.34.110 (a vulnerable adult may seek relief from financial exploitation by filing a petition for a protection order), .”
Brown v. Dep't of Soc. & Health Servs., 145 Wash. App. 177 (Wash. Ct. App. 2008). “020(2). Abuse includes “physical abuse,” which is defined as “the willful action of inflicting bodily injury or physical mistreatment.”
Brown v. State, Dept. of Soc. & Health Servs., 185 P.3d 1210 (Wash. Ct. App. 2008). “Abuse includes "physical abuse," which is defined as "the willful action of inflicting bodily injury or physical mistreatment.”
Endicott v. Saul, 176 P.3d 560 (Wash. Ct. App. 2008). “110(2) provides that: A petition shall allege that the petitioner is a vulnerable adult and that the petitioner has been abandoned, abused, financially exploited, or neglected, or is threatened with abandonment, abuse, financial exploitation, or neglect by respondent.”
In Re The Matter Of Thomas J. Winter v. Morris A. Winter (Wash. Ct. App. 2020). “Agreed Application to Vacate the VAPO When a vulnerable adult who has not been adjudicated fully incapacitated applies to the court for modification or vacation of a VAPO, “the court shall grant such relief consistent with RCW 74.34.110 as it deems necessary for the protection…”
In the Matter of the Vulnerable Adult Petition for: Alan Carlin (Wash. Ct. App. 2021). “135(3): At the hearing scheduled by the court, the court shall give the vulnerable adult, the respondent, the petitioner, and in the court’s discretion other interested persons, the opportunity to testify and submit relevant evidence.”
In re the Matter of: James Donald Cudmore & John C. Bolliger (Wash. Ct. App. 2016). “Bolliger under RCW 74.34.110, seeking to limit Mr. Bolliger's contact with Mr.”
— Wash. Rev. Code § 74.34.110(1) — 9 cases
Knight v. Knight, 317 P.3d 1068 (Wash. Ct. App. 2014). “RCW 74.34.110. “A vulnerable adult, or interested person on behalf of the vulnerable adult, may [file] a petition for an order for protection in superior court.”
In the Matter of the Vulnerable Adult Petition for: Alan Carlin (Wash. Ct. App. 2021). “135(3): At the hearing scheduled by the court, the court shall give the vulnerable adult, the respondent, the petitioner, and in the court’s discretion other interested persons, the opportunity to testify and submit relevant evidence.”
Marcus Price v. Antoinette S. Price (Wash. Ct. App. 2020).
In re the Matter of: James Donald Cudmore & John C. Bolliger (Wash. Ct. App. 2016). “Bolliger under RCW 74.34.110, seeking to limit Mr. Bolliger's contact with Mr.”
In Re The Matter Of Thomas J. Winter v. Morris A. Winter (Wash. Ct. App. 2020). “Agreed Application to Vacate the VAPO When a vulnerable adult who has not been adjudicated fully incapacitated applies to the court for modification or vacation of a VAPO, “the court shall grant such relief consistent with RCW 74.34.110 as it deems necessary for the protection…”
— Wash. Rev. Code § 74.34.110(2) — 8 cases
Endicott v. Saul, 142 Wash. App. 899 (Wash. Ct. App. 2008). “110(2) provides that [a] petition shall allege that the petitioner is a vulnerable adult and that the petitioner has been abandoned, abused, financially exploited, or neglected, or is threatened with abandonment, abuse, financial exploitation, or neglect by respondent.”
Knight v. Knight, 317 P.3d 1068 (Wash. Ct. App. 2014). “RCW 74.34.110. “A vulnerable adult, or interested person on behalf of the vulnerable adult, may [file] a petition for an order for protection in superior court.”
Endicott v. Saul, 176 P.3d 560 (Wash. Ct. App. 2008). “110(2) provides that: A petition shall allege that the petitioner is a vulnerable adult and that the petitioner has been abandoned, abused, financially exploited, or neglected, or is threatened with abandonment, abuse, financial exploitation, or neglect by respondent.”
In Re The Matter Of Thomas J. Winter v. Morris A. Winter (Wash. Ct. App. 2020). “Agreed Application to Vacate the VAPO When a vulnerable adult who has not been adjudicated fully incapacitated applies to the court for modification or vacation of a VAPO, “the court shall grant such relief consistent with RCW 74.34.110 as it deems necessary for the protection…”
Marcus Price v. Antoinette S. Price (Wash. Ct. App. 2020).
— Wash. Rev. Code § 74.34.110(3) — 4 cases
In Re The Matter Of Thomas J. Winter v. Morris A. Winter (Wash. Ct. App. 2020). “Agreed Application to Vacate the VAPO When a vulnerable adult who has not been adjudicated fully incapacitated applies to the court for modification or vacation of a VAPO, “the court shall grant such relief consistent with RCW 74.34.110 as it deems necessary for the protection…”
In re the Matter of: James Donald Cudmore & John C. Bolliger (Wash. Ct. App. 2016). “Bolliger under RCW 74.34.110, seeking to limit Mr. Bolliger's contact with Mr.”
In Re The Matter Of Paul Locke Partners In Care v. Will Knedlik (Wash. Ct. App. 2021).
Orville Moe v. Aaron Goforth (Wash. Ct. App. 2013).
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