WA State District Courts, Multiple Defendants & Jurisdictional Caps
The relevant statute is Chapter 3.66.020 RCW, which–as of the date of this article–states as follows:
If, for each claimant, the value of the claim or the amount at issue does not exceed one hundred thousand dollars, exclusive of interest, costs, and attorneys' fees, the district court shall have jurisdiction and cognizance of the following civil actions and proceedings:
(1) Actions arising on contract for the recovery of money;
(2) Actions for damages for injuries to the person, or for taking or detaining personal property, or for injuring personal property, or for an injury to real property when no issue raised by the answer involves the plaintiff's title to or possession of the same and actions to recover the possession of personal property;
(3) Actions for a penalty;
(4) Actions upon a bond conditioned for the payment of money, when the amount claimed does not exceed fifty thousand dollars, though the penalty of the bond exceeds that sum, the judgment to be given for the sum actually due, not exceeding the amount claimed in the complaint;
(5) Actions on an undertaking or surety bond taken by the court;
(6) Actions for damages for fraud in the sale, purchase, or exchange of personal property;
(7) Proceedings to take and enter judgment on confession of a defendant;
(8) Proceedings to issue writs of attachment, garnishment and replevin upon goods, chattels, moneys, and effects;
(9) Actions arising under the provisions of chapter 19.190 RCW;
(10) Proceedings to civilly enforce any money judgment entered in any municipal court or municipal department of a district court organized under the laws of this state; and
(11) All other actions and proceedings of which jurisdiction is specially conferred by statute, when the title to, or right of possession of, real property is not involved.
Id. (NOTE: Statutory dollar figures are always subject to change; visit the Washington State Legislature Website for current dollar figures) (emphasis added).THE LAW APPLIED TO MULTIPLE DEFENDANTS
It is unclear whether the jurisdictional cap under RCW 3.66.020–in the case of a lawsuit in district court against multiple defendants–applies either to the action as a whole or separately as to each group of claims against each individual defendant. However, in 1986, Division 2 of the Washington State Court of Appeals addressed a similar issue in Rasmussen v. Chase, 720 P.2d 860, 44 Wn.App. 71 (Div. 2 1986), thereby creating what I call the “Chase Rule”; and to this day, over 30 years later, no court has overruled the decision. See id.
In Rasmussen v. Chase, the Chases leased property from Rasmussen in 1980 agreeing to make monthly payments of $2,250. Id. Thereafter, the Chases failed to make lease payments from August 1982 through January 1983. Id. Accordingly, Rasmussen filed three separately ongoing lawsuits in Pierce County District Court against the Chases for rent due: the first lawsuit claimed rent due for August and September, 1982; the second lawsuit claimed rent due for October and November, 1982; and the third lawsuit claimed rent due for December, 1982 and January, 1983. Id.
The Chases argued that the single lawsuit contained a prayer amount which was beyond the court’s jurisdiction and that the court was thereupon divested of jurisdiction. However, on review, the Chase Court held as follows:
In our view [RCW 3.66.020] confers—and limits—jurisdiction over causes of action and not over lawsuits to the extent that the latter are merely vehicles for the former…We conclude that consolidation is proper if the causes of action consolidated, considered separately, are within the District Court’s jurisdictional limits… [The district court’s jurisdiction] depend[s] upon the amount in controversy in a given cause of action.
Rasmussen v. Chase, 44 Wn.App. at 73-74 (hyperlink added to original) (emphasis added).THE CHASE RULE
Under Rasmussen v. Chase, the statutory cap for WA District Courts applies to causes of action and not individual defendants. Thus, if a plaintiff pursues multiple causes of action against each of multiple defendants within a single lawsuit, then, arguably, the plaintiff would be entitled to seek up to $100,000 for each cause of action against each defendant.
CONCLUSION
I would argue that according to the Chase Rule, WA State District Courts maintain jurisdiction over a single lawsuit involving multiple defendants in which the combined "value of the claim or amount at issue" is above the current statutory cap of $100,000, as long as each cause of action against each individual defendant is below the statutory cap — $100,000 as of the date of this article.
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