Renner v. City of Marysville, 168 Wash. 2d 540

Summary

The Supreme Court of Washington held that Marc Renner substantially complied with former RCW 4.96.020(3), which governed tort claim filings against local governments. Renner's description of his damages, rather than a numerical amount, and his incomplete residential address information were sufficient because the filing fulfilled the statute's purposes of providing notice and allowing investigation and settlement. The court affirmed the Court of Appeals and remanded for further proceedings.

Holdings

1. A claimant substantially complies with the statute's amount-of-damages requirement by providing an accurate and complete general description of the damages sought when that information fulfills the statutory purposes of notifying the local government of the claim and allowing it to investigate, negotiate, and potentially settle the claim; a numerical damages figure is not invariably required.
2. A claimant substantially complies with the residence requirement when the information provided is a bona fide attempt and fulfills the statute's purpose of identifying and locating the claimant, including when the municipality can determine missing residence information through reasonable diligence.

Questions Presented

1. Whether a claimant substantially complies with former RCW 4.96.020(3) by describing the types of damages sought rather than stating a numerical amount.
2. Whether a claimant substantially complies with the statute's residence-information requirement by providing one address covering only part of the six-month period when the municipality can determine the remaining information through reasonable diligence.

Disposition

affirmed