Hawkins v. Diel, 166 Wash. App. 1 (2011)

Citation: Hawkins v. Diel, 166 Wash. App. 1 (2011)
Parent Document: Hawkins v. Diel, 166 Wash. App. 1 (2011)
Jurisdiction: Washington (state)
Effective Date: 2011-11-18
Original Source: https://www.courtlistener.com/opinion/4950936/hawkins-v-diel/ ↗

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¶16 We award attorney fees only if authorized by a contract, statute, or recognized ground in equity. Bowles v. Dep’t of Ret. Sys., 121 Wn.2d 52, 70, 847 P.2d 440 (1993). We review de novo a trial court’s decision that a particular *10contract, statute, or recognized ground in equity authorizes an attorney fee award. Tradewell Grp., Inc. v. Mavis, 71 Wn. App. 120, 126, 857 P.2d 1053 (1993). The lease here allowed for attorney fees, which applies to the Hawkinses through RCW 4.84.330. See Wachovia SBA Lending, Inc. v. Kraft, 165 Wn.2d 481, 489, 200 P.3d 683 (2009) (“By its plain language, the purpose of RCW 4.84.330 is to make unilateral contract provisions bilateral.”).

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