Wash. Rev. Code » Title 74 · Chapter 74.34
Revised Code of Washington

Wash. Rev. Code § 74.34.200 (2026)

✓ current as of May 2026
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(1) In addition to other remedies available under the law, a vulnerable adult who has been subjected to abandonment, abuse, financial exploitation, or neglect either while residing in a facility or in the case of a person residing at home who receives care from a home health, hospice, or home care agency, or an individual provider, shall have a cause of action for damages on account of his or her injuries, pain and suffering, and loss of property sustained thereby. This action shall be available where the defendant is or was a corporation, trust, unincorporated association, partnership, administrator, employee, agent, officer, partner, or director of a facility, or of a home health, hospice, or home care agency licensed or required to be licensed under chapter 70.127 RCW, as now or subsequently designated, or an individual provider.
(2) It is the intent of the legislature, however, that where there is a dispute about the care or treatment of a vulnerable adult, the parties should use the least formal means available to try to resolve the dispute. Where feasible, parties are encouraged but not mandated to employ direct discussion with the health care provider, use of the long-term care ombuds or other intermediaries, and, when necessary, recourse through licensing or other regulatory authorities.
(3) In an action brought under this section, a prevailing plaintiff shall be awarded his or her actual damages, together with the costs of the suit, including a reasonable attorneys' fee. The term "costs" includes, but is not limited to, the reasonable fees for a guardian, guardian ad litem, and experts, if any, that may be necessary to the litigation of a claim brought under this section.
[ 2013 c 23 s 219; 1999 c 176 s 15; 1995 1st sp.s. c 18 s 85.]

Notes:

Findings—Purpose—Severability—Conflict with federal requirements—1999 c 176: See notes following RCW 74.34.005.
Conflict with federal requirements—Severability—Effective date—1995 1st sp.s. c 18: See notes following RCW 74.39A.030.
Notes of Decisions
Cited in 39 cases (11 in the last 5 years), 2001–2026 · leading case: Kim v. Lakeside Adult Fam. Home, 374 P.3d 121 (Wash. 2016).
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Kim v. Lakeside Adult Fam. Home, 374 P.3d 121 (Wash. 2016). · cites it 2× “¶64 Separately, Kim argues that assuming she prevails at trial, she is entitled to an award of attorney fees both at trial and on appeal pursuant to RCW 74.34.200. Br. of Appellants at 31. Because Kim has not yet prevailed at trial, her claim to fees is also premature.”
Conrad v. Manor, 78 P.3d 177 (Wash. Ct. App. 2003). · cites it 4× “Tay Conrad, as personal representative of the estate of his mother Enid Conrad, and his father Wafford Conrad *280 (Conrad) sued Alderwood Manor, Consolidated Resources Health Care Fund One LP, and Life Care Centers of America (Alderwood), setting out causes of action in common…”
Conrad Ex Rel. Conrad v. Alderwood Manor, 78 P.3d 177 (Wash. Ct. App. 2003). · cites it 4× “Tay Conrad, as personal representative of the estate of his mother Enid Conrad, and his father Wafford Conrad (Conrad) sued Alderwood Manor, Consolidated Resources Health Care Fund One LP, and Life Care Centers of America (Alderwood) setting out causes of action in common law…”
Scott Woodward v. Emeritus Corp., 368 P.3d 487 (Wash. Ct. App. 2016). · cites it 4× “¶1 Emeritus Corporation, its affiliate, and two employees appeal the denial of their motion to compel arbitration of claims for negligence and violation of Washington’s vulnerable adult statute (RCW 74.34.200) brought against them by Scott Woodward, as personal representative of…”
Goldsmith v. Dep't of Soc. & Health Servs., 280 P.3d 1173 (Wash. Ct. App. 2012). · cites it 4× “210 and the cause of action RCW 74.34.200 creates. When the legislature adopted the abuse of vulnerable adults act, chapter 74.”
Donohoe v. State, 135 Wash. App. 824 (Wash. Ct. App. 2006). · cites it 3× “RCW 74.34.200, significantly titled “Abandonment, abuse, financial exploitation, or neglect of a vulnerable adult — Cause of action for damages— Legislative intent,” provides, in pertinent part: (1) In addition to other remedies available under the law, a vulnerable adult who…”
Donohoe v. State, 142 P.3d 654 (Wash. Ct. App. 2006). · cites it 3× “RCW 74.34.200, significantly titled, "Abandonment, abuse, financial exploitation, or neglect of a vulnerable adult — Cause of action for damages — Legislative intent," provides, in pertinent part: (1) In addition to other remedies available under the law, a vulnerable adult who…”
Cummings v. Guardianship Servs., 110 P.3d 796 (Wash. Ct. App. 2005). · cites it 3× “005 provides: The legislature finds that the availability of home health, hospice, and home care services has improved the quality of life for Washington’s citizens.”
Calhoun v. State, 146 Wash. App. 877 (Wash. Ct. App. 2008). · cites it 5× “8 Calhoun later amended his complaint to include two additional *883 relevant claims: (1) abuse of a vulnerable adult in violation of RCW 74.34.200 and (2) official misconduct in violation of RCW 74.”
Schumacher v. Williams, 28 P.3d 792 (Wash. Ct. App. 2001). “010 provides: When the death of a person is caused by the wrongful act, neglect or default of another his personal representative may maintain an action for damages against the person causing the death; and although the death shall have been caused under such circumstances as…”
Schumacher v. Williams, 107 Wash. App. 793 (Wash. Ct. App. 2001). “RCW 74.34.200. State v. Sullivan, 143 Wn.”
Est. OF ECKSTEIN EX REL. LUCKEY v. Life Care Centers of Am., 623 F. Supp. 2d 1235 (E.D. Wash. 2009). · cites it 2× “Defendants further assure that they will not take the position that Plaintiff would be precluded from recovering attorneys’ fees, pursuant to the provisions of RCW 74.34.200, should she prevail on that claim in arbitration.”
Show all 39 citing cases →
— Wash. Rev. Code § 74.34.200(1) — 19 cases
Kim v. Lakeside Adult Fam. Home, 374 P.3d 121 (Wash. 2016). “¶64 Separately, Kim argues that assuming she prevails at trial, she is entitled to an award of attorney fees both at trial and on appeal pursuant to RCW 74.34.200. Br. of Appellants at 31. Because Kim has not yet prevailed at trial, her claim to fees is also premature.”
Donohoe v. State, 135 Wash. App. 824 (Wash. Ct. App. 2006). “RCW 74.34.200, significantly titled “Abandonment, abuse, financial exploitation, or neglect of a vulnerable adult — Cause of action for damages— Legislative intent,” provides, in pertinent part: (1) In addition to other remedies available under the law, a vulnerable adult who…”
Donohoe v. State, 142 P.3d 654 (Wash. Ct. App. 2006). “RCW 74.34.200, significantly titled, "Abandonment, abuse, financial exploitation, or neglect of a vulnerable adult — Cause of action for damages — Legislative intent," provides, in pertinent part: (1) In addition to other remedies available under the law, a vulnerable adult who…”
Goldsmith v. Dep't of Soc. & Health Servs., 280 P.3d 1173 (Wash. Ct. App. 2012). “210 and the cause of action RCW 74.34.200 creates. When the legislature adopted the abuse of vulnerable adults act, chapter 74.”
Cummings v. Guardianship Servs., 110 P.3d 796 (Wash. Ct. App. 2005). “005 provides: The legislature finds that the availability of home health, hospice, and home care services has improved the quality of life for Washington’s citizens.”
— Wash. Rev. Code § 74.34.200(3) — 10 cases
Conrad v. Manor, 78 P.3d 177 (Wash. Ct. App. 2003). “Tay Conrad, as personal representative of the estate of his mother Enid Conrad, and his father Wafford Conrad *280 (Conrad) sued Alderwood Manor, Consolidated Resources Health Care Fund One LP, and Life Care Centers of America (Alderwood), setting out causes of action in common…”
Conrad Ex Rel. Conrad v. Alderwood Manor, 78 P.3d 177 (Wash. Ct. App. 2003). “Tay Conrad, as personal representative of the estate of his mother Enid Conrad, and his father Wafford Conrad (Conrad) sued Alderwood Manor, Consolidated Resources Health Care Fund One LP, and Life Care Centers of America (Alderwood) setting out causes of action in common law…”
Scott Woodward v. Emeritus Corp., 368 P.3d 487 (Wash. Ct. App. 2016). “¶1 Emeritus Corporation, its affiliate, and two employees appeal the denial of their motion to compel arbitration of claims for negligence and violation of Washington’s vulnerable adult statute (RCW 74.34.200) brought against them by Scott Woodward, as personal representative of…”
Carlton v. Vancouver Care, LLC, 231 P.3d 1241 (Wash. Ct. App. 2010).
Est. OF ECKSTEIN EX REL. LUCKEY v. Life Care Centers of Am., 623 F. Supp. 2d 1235 (E.D. Wash. 2009). “Defendants further assure that they will not take the position that Plaintiff would be precluded from recovering attorneys’ fees, pursuant to the provisions of RCW 74.34.200, should she prevail on that claim in arbitration.”
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