Washington Supreme Court

Silver v. Rudeen Mgmt. Co., Inc.

April 22, 2021197 Wash. 2d 535

Summary

The Washington Supreme Court held that a tenant’s action to recover a security deposit under RCW 59.18.280 is an action to recover personal property and therefore is governed by the three‑year statute of limitations in RCW 4.16.080(2); the complaint was timely, the trial court’s dismissal was erroneous, and the case was reversed and remanded for further proceedings on attorney‑fees issues.

Holding

  • What statute of limitations applies to an action brought under RCW 59.18.280 to recover a security deposit?. The three‑year limitations period in RCW 4.16.080(2) applies because the action is to recover the tenant’s personal property.

Docket 98024-1

Cited authorities

  • 42 U.S.C. §§ 3601-3619

Cited by