Revised Code of Washington
Wash. Rev. Code § 84.64.180 (2026)
✓ current as of May 2026
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Deeds executed by the county treasurer, as aforesaid, shall be prima facie evidence in all controversies and suits in relation to the right of the purchaser, his or her heirs and assigns, to the real property thereby conveyed of the following facts: First, that the real property conveyed was subject to taxation at the time the same was assessed, and had been listed and assessed in the time and manner required by law; second, that the taxes were not paid at any time before the issuance of deed; third, that the real property conveyed had not been redeemed from the sale at the date of the deed; fourth, that the real property was sold for taxes, interest, and costs, as stated in the deed; fifth, that the grantee in the deed was the purchaser, or assignee of the purchaser; sixth, that the sale was conducted in the manner required by law. And any judgment for the deed to real property sold for delinquent taxes rendered after January 9, 1926, except as otherwise provided in this section, shall estop all parties from raising any objections thereto, or to a tax title based thereon, which existed at or before the rendition of such judgment, and could have been presented as a defense to the application for such judgment in the court wherein the same was rendered, and as to all such questions the judgment itself shall be conclusive evidence of its regularity and validity in all collateral proceedings, except in cases where the tax has been paid, or the real property was not liable to the tax.
[ 2013 c 23 s 377; 1961 c 15 s 84.64.180. Prior: 1925 ex.s. c 130 s 127; RRS s 11288; prior: 1897 c 71 s 114; 1893 c 124 s 132; 1890 p 574 s 114.]
Notes of Decisions
Cited in 9
cases (1 in the last 5 years), 1958–2024 · leading case: Smith v. Henley, 330 P.2d 712 (Wash. 1958).
Smith v. Henley, 330 P.2d 712 (Wash. 1958). “RCW 84.64.180 provides that a real property tax judgment shall be conclusive evidence of its regularity and validity in all collateral proceedings, except in cases where the tax has been paid, or the real property was not liable to the tax.”
In Re Proceedings of King Cnty. Foreclosure of Liens, 811 P.2d 945 (Wash. 1991). “To prevent the upset of tax sales and to assure the stability of tax deeds, RCW 84.64.180 provides that a tax deed is prima facie evidence of the regularity of all proceedings leading up to the tax sale, and prevents the parties from raising any objections to the proceedings…”
Fitzgerald v. Neves, Inc., 550 P.2d 52 (Wash. Ct. App. 1976). “(RCW 84.64.180 lists the first two exceptions as “cases where the tax has been paid, or the real property was not liable to the tax.”
Label v. Cleasby, 537 P.2d 859 (Wash. Ct. App. 1975). “) Cleasby argues that disputes between holders by adverse possession and holders by tax deed are resolved in Washington by a consideration of the relative equities favoring each of the parties, but we reject such a broad statement.”
Bornstein Sea Foods, Inc. v. Whatcom Cnty., 345 P.2d 601 (Wash. 1959). “) The only two grounds provided by the statute (RCW 84.64.180) for collaterally attacking a tax foreclosure judgment are (1) proof that the taxes had been paid, and (2) that the land was not subject to taxation.”
Us Bank Nat'l Assn, V. David Vournas (Wash. Ct. App. 2024). “180 provides that tax deeds “shall be prima facie evidence in all controversies and suits in relation to the right of the purchaser, his or her heirs and assigns, to the real property thereby conveyed” of several facts, including that the parcel “was subject to taxation at the…”
Us Bank v. North Am. Title Co. (Wash. Ct. App. 2016). “74843-2-1 / 6 However, RCW 84.64.180 provides two exceptions to the finality of a tax deed: And any judgment for the deed to real property sold for delinquent taxes rendered after January 9, 1926, except as otherwise provided in this section, shall estop all parties from raising…”
Pierce Cnty. v. Schwab, 739 P.2d 116 (Wash. Ct. App. 1987). “180 declares (among other things) that the tax deed is prima facie evidence that the property was sold for taxes, interest and costs as reflected in the deed, and that the sale was conducted in the manner required by law.”
In Re Proceeding For Kitsap Co Foreclosure Leins 2011 (Wash. Ct. App. 2018). “" RCW 84.64.180. When a tax title is sought to be overthrown,"the burden is on the one who asserts its invalidity to overcome the deed by competent and controlling evidence.”
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