Revised Code of Washington

Wash. Rev. Code § 9.68A.130 (2026)

Recovery of costs of suit by minor

✓ current as of May 2026
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A minor prevailing in a civil action arising from violation of this chapter is entitled to recover the costs of the suit, including an award of reasonable attorneys' fees.
[ 1984 c 262 s 12.]
Notes of Decisions
Cited in 10 cases (2 in the last 5 years), 2006–2025 · leading case: Shari Furnstahl v. Jonnie Barr & Sue Barr, 389 P.3d 635 (Wash. Ct. App. 2016).
Shari Furnstahl v. Jonnie Barr & Sue Barr, 389 P.3d 635 (Wash. Ct. App. 2016). · cites it 20× “¶1 An award of attorney fees pursuant to RCW 9.68A.130 is contingent on a fact finder’s determination that the party seeking the award prevailed in an action arising from conduct constituting a violation of a provision of chapter 9.”
J.C. v. Soc'y of Jesus, 457 F. Supp. 2d 1201 (W.D. Wash. 2006). · cites it 14× “RCW § 9.68A.130 Plaintiffs claim under the Sexual Exploitation of Children Act (“SECA”) presents questions of statutory construction.”
Ohnemus v. State, 379 P.3d 142 (Wash. Ct. App. 2016). · cites it 4× “100, and therefore, the State is *138 not liable to Ohnemus for costs and fees under RCW 9.68A.130. In the unpublished portion of this opinion, we affirm the superior court’s summary judgment dismissal of Ohnemus’s negligence claims against the State.”
Kuhn v. Schnall, 228 P.3d 828 (Wash. Ct. App. 2010). · cites it 2× “¶6 The court allowed plaintiffs to amend their complaints to assert claims for attorney fees under RCW 9.68A.130 based on allegations that Schnall had communicated for immoral purposes with the patient-plaintiffs while they were minors, in violation of RCW 9.”
Boy 1 v. Boy Scouts of Am., 832 F. Supp. 2d 1282 (W.D. Wash. 2011). · cites it 3× “” RCW 9.68A.130. Defendants argue that, because Plaintiffs do not allege that the Plaintiffs’ scout leader perpetrators were charged with SECA violations, no civil cause of action may be brought for a “violation” of SECA, and therefore attorneys fees cannot be awarded under RCW…”
State v. J.H.-M., 566 P.3d 847 (Wash. 2025). “claims, results in vagueness because it is not clear what is prohibited.”
Kuhn v. Schall, 228 P.3d 828 (Wash. Ct. App. 2010). · cites it 3× “*831 ¶ 6 The court allowed plaintiffs to amend their complaints to assert claims for attorney fees under RCW 9.68A.130 based on allegations that Schnall had communicated for immoral purposes with the patient-plaintiffs while they were minors, in violation of RCW 9.”
Tasha Ohnemus, Res/cross-appellant v. State Of Washington, App./cross-respondent (Wash. Ct. App. 2016). · cites it 4× “100, and therefore, the State is not liable to Ohnemus for costs and fees under RCW 9.68A.130. In the unpublished portion of this opinion, we affirm the superior court’s summary judgment dismissal of Ohnemus’s negligence claims against the State.”
M.L. v. craigslist Inc (W.D. Wash. 2020). · cites it 2× “9 RCW 9.68A.130 provides that a minor is entitled to recover costs and attorneys’ 10 fees if the minor prevails in a civil action arising from violation of SECA.”
Liberty Mut. Ins. Co. v. Lange (W.D. Wash. 2023). · cites it 2× “9), and that the Langes 19 “are each liable under RCW 9.68A.130 for facilitating the abuse and neglect of 20 C.”
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