fees in the amount of $15,225.50.
Silver appealed, and the Court of Appeals affirmed. Silver v. Rudeen Mgmt.
Co., 10 Wn. App. 2d 676, 449 P.3d 1067 (2019). The Court of Appeals rejected
Silver’s argument that the three-year statute of limitations under RCW 4.16.080(2)
should apply because he filed an action for return of personal property. It concluded
that the two-year catchall statute of limitations applied because Silver had filed “an
action to enforce the deposit return obligation of the RLTA,” and an action to enforce
4
We assume, without deciding, that the trial court correctly concluded that the cause of
action accrued on July 15, 2015 (14 days after the date Silver vacated and Rudeen sent the
preliminary deposit statement).
5
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Silver v. Rudeen Mgmt. Co.
No. 98024-1
a statute should fall under RCW 4.16.130. Id. at 681. Therefore, the court reasoned,
the trial court correctly dismissed the action because it was commenced more than
two years after it had accrued. Id. Silver filed a petition for review in this court,
which we granted. 195 Wn.2d 1018 (2020).
II. ANALYSIS
The RLTA does not include a statute of limitations, but chapter 4.16 RCW
provides statutes of limitations for various categories of actions. RCW 4.16.080(2)
limits actions to three years for “[a]n action for taking, detaining, or injuring personal
property, including an action for the specific recovery thereof, or for any other injury
to the person or rights of another not hereinafter enumerated.” In contrast, the
catchall statute limits actions to two years for “[a]n action for relief not hereinbefore
provided for.” RCW 4.16.130 (emphasis added). We hold that the three-year statute