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Sunday, February 4, 2018

WA State District Courts, Multiple Defendants & Jurisdictional Caps

by Gregory Williams, Esq. | As of the date of this article, the jurisdictional cap for actions filed in WA State District Courts is $100,000 (see RCW 3.66.020 for current law/dollar amounts); but what is the jurisdictional cap if one filed a lawsuit involving multiple defendants in a district court? Here’s my point of view (NOTE: please read our DISCLAIMER before proceeding).

CHAPTER 3.66.020 RCW

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.

RASMUSSEN v. CHASE: LAWSUITS & CAUSES OF ACTION

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. All three cases were subsequently consolidated with a combined prayer over the jurisdictional cap for Pierce County District Court. Id. Thus, the court was presented with a single lawsuit containing multiple causes of action–each for rent past due for a unique timeframe–against the same defendants: the Chases.

The Chases then 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 Court of Appeals then applied the Chase Rule and held that the first lawsuit was based on one cause of action and within the jurisdictional limit; while the second and third lawsuits should be combined as one cause of action, again within the jurisdictional limit – and jurisdiction was proper even though both causes of action together in one lawsuit were well beyond the jurisdictional limit. See Id.

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. Again, keep in mind that statutory dollar figures are always subject to change; visit the Washington State Legislature Website for current dollar figures. See RCW 3.66.020.


LEARN MORE

If you would like to learn more, then consider contacting an experienced Washington State Attorney as soon as possible to discuss your case. Please note: the information contained in this article is not offered as legal advice and will not form an attorney-client relationship with either this author or Williams Law Group, PS; please see our DISCLAIMER.

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