Summary
The Supreme Court of Washington held that the filing restrictions in former RCW 4.12.020(3) concern venue rather than subject matter jurisdiction among superior courts. The court overruled Aydelotte v. Audette, reversed the Court of Appeals, and remanded the case for further proceedings. The decision arose from a negligence action involving an automobile accident and addressed the restrictions' consistency with article IV, section 6 of the Washington Constitution.
Topics
Practice areas
Questions Presented
- Whether former RCW 4.12.020(3), which specified counties in which motor-vehicle-accident actions could be filed, limited subject matter jurisdiction among Washington superior courts or merely governed venue.
- Whether construing RCW 4.12.020(3) as limiting subject matter jurisdiction among superior courts violated article IV, section 6 of the Washington Constitution.
Holdings
- The filing restrictions in RCW 4.12.020(3) relate only to venue and do not limit subject matter jurisdiction among Washington superior courts.
- The Snohomish County Superior Court should not have dismissed the action for lack of subject matter jurisdiction based on RCW 4.12.020(3); the Court of Appeals' decision affirming dismissal is reversed.
Key quotations
“We hold RCW 4.12.020 relates only to venue, overruling Aydelotte v. Audette, 110 Wash.2d 249, 253, 750 P.2d 1276 (1988), and reverse the Court of Appeals.” (149 Wash. 2d at 130)
“We overrule Aydelotte and hold the filing restrictions of RCW 4.12.020(3) relate only to the venue in which such actions may be tried.” (149 Wash. 2d at 134)
Factual background
An automobile accident involving William and Colleen Young and Arthur Clark occurred in Kittitas County on July 27, 1997. After William Young died, Colleen Young sued Arthur and Jane Doe Clark in Snohomish County for negligence, although Young resided in Snohomish County and the Clarks resided in Pierce County. The defendants moved for judgment on the pleadings shortly before the statute of limitations expired, arguing that former RCW 4.12.020(3) deprived the Snohomish County Superior Court of subject matter jurisdiction.
Procedural history
Young filed a negligence action in Snohomish County arising from a Kittitas County automobile accident. The defendants moved for judgment on the pleadings, asserting that former RCW 4.12.020(3) deprived the Snohomish County Superior Court of subject matter jurisdiction. The trial court dismissed the action and did not consider Young's motion to add defendants or Allstate's motion to intervene; the Court of Appeals affirmed. The Washington Supreme Court accepted discretionary review, reversed, and remanded.
Remand instructions
Remanded to the trial court for further proceedings consistent with the decision. The petitioner shall recover her costs.