Revised Code of Washington
Wash. Rev. Code § 9.92.120 (2026)
Conviction of public officer forfeits trust
✓ current as of May 2026
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The conviction of a public officer of any felony or malfeasance in office shall entail, in addition to such other penalty as may be imposed, the forfeiture of his or her office, and shall disqualify him or her from ever afterward holding any public office in this state.
[ 2011 c 336 s 333; 1909 c 249 s 37; RRS s 2289.]
Notes:
Forfeiture or impeachment, rights preserved: RCW 42.04.040.
Misconduct of public officers: Chapter 42.20 RCW.
Vacancy of public office, causes: RCW 42.12.010.
Notes of Decisions
Cited in 16
cases (2 in the last 5 years), 1962–2024 · leading case: Lee v. Jasman, 332 P.3d 1106 (Wash. Ct. App. 2014).
Lee v. Jasman, 332 P.3d 1106 (Wash. Ct. App. 2014). “The specific question we address is whether one who holds the position of deputy county coroner and performs the task of signing death certificates is a “public officer” subject to disqualification under RCW 9.92.120 because of a conviction of a crime.”
State Ex Rel. Zempel v. Twitchell, 367 P.2d 985 (Wash. 1962). “" and RCW 9.92.120, which reads: "The conviction of a public officer of any felony or malfeasance in office shall entail, in addition to such other penalty as may be imposed, the forfeiture of his office, and shall disqualify him from ever afterward holding any public office in…”
Hoflin v. City of Ocean Shores, 847 P.2d 428 (Wash. 1993). “Valdez that he interpreted RCW 9.92.120 9 to mean that "a conviction followed by judgment and sentence automatically terminates a public office whether elected or appointed .”
Matsen v. Kaiser, 443 P.2d 843 (Wash. 1968). “) RCW 9.92.120. It is now invoked against the Sheriff of Klickitat County to oust him from office.”
Grant Cnty. Prosecuting Attorney v. Jasman, 354 P.3d 846 (Wash. 2015). “RCW 9.92.120. However, the *637 new Grant County coroner, Craig Morrison, quickly hired Jasman as chief deputy coroner and chief investigator.”
Kitsap Cnty. Repub. Cent. Comm. v. Huff, 620 P.2d 986 (Wash. 1980). “In addition, RCW 9.92.120 provides that The conviction of a public officer of any felony or malfeasance in office shall entail, in addition to such other penalty as may be imposed, the forfeiture of his office, and shall disqualify him.”
In Re the Disciplinary Proceedings Against Simmons, 395 P.2d 1013 (Wash. 1964). “(4) By the terms of RCW 9.92.120 and 42.12.010 respondent's conviction, on February 21, 1961, of the felony with which he was charged carried with it the immediate forfeiture of his office as judge of the Municipal Court of the City of Seattle, and then created a vacancy in that…”
State v. Smith, 246 P.3d 812 (Wash. Ct. App. 2010). “24 A voter brought suit, claiming that Kaiser’s conviction disqualified him from holding office within the meaning of RCW 9.92.120. 25 ¶19 None of the three opinions filed in Matsen garnered a majority vote.”
State v. Tate, 469 P.2d 999 (Wash. Ct. App. 1970). “Kaiser involved interpretation and application of RCW 9.92.120 relating to disqualification of a public official who has been convicted of a felony.”
D. Angus Lee v. Jerry Jasman (Wash. Ct. App. 2014). “The specific question we address is whether one who holds the position of deputy county coroner and performs the task of signing death certificates is a "public officer" subject to disqualification under RCW 9.92.120 because ofa conviction ofa crime? We answer in the affirmative…”
Hoflin v. City of Ocean Shores, 819 P.2d 403 (Wash. Ct. App. 1991). “The city manager, on the advice of the city attorney, notified Hoflin that Ocean Shores had no choice but to fire him because of the provisions of RCW 9.92.120. 2 Hoflin was invited to respond, but he did not and was terminated.”
Mun. Court ex rel. Tuberg v. Beighle, 622 P.2d 405 (Wash. Ct. App. 1981). “" RCW 9.92.120 provides for forfeiture of public office upon conviction of any felony or malfeasance in office.”
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