Wash. Supreme Court published opinion — 1013299.pdf

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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Crossroads Management, LLC v. Ridgway et al., No. 101329-9

sign the trial de novo request because the county required e-filing during the

COVID-19 pandemic yet provided a defective form. We reject this argument.

Our case law has long mandated strict compliance. We have repeatedly and

unequivocally held that lack of full compliance with the SCCARs will invalidate a

trial de novo request. For example, in Wiley, two of the three defendants filed a trial

de novo request but mistakenly omitted the name of the third defendant. 143 Wn.2d

at 342. We rejected the trial de novo request, concluding that the failure to include

all the defendants’ names “is not an inconsequential error, but rather is a failure to

strictly comply with the requirements [of the SCCARs].” Id. at 345. In Pybas v.

Paolino, an attorney entrusted a trial de novo request with a legal messenger. 73

Wn. App. 393, 395, 869 P.2d 427 (1994). The messenger failed to file the notice

within the 20-day deadline, and the Court of Appeals concluded the party was not

entitled to a trial de novo. Id. at 404-05. As a final example, the attorney in State

ex rel. J.M.H. v. Hofer was unable to timely file the request because he suffered a

head injury and his hospital stay overlapped with the 20-day deadline. 86 Wn. App.

497, 498, 942 P.2d 979 (1997). Nonetheless, the Court of Appeals held the trial de

novo request was ineffective in the absence of a timely filing. Id. The case law

underscores the importance of strict compliance with the arbitration statutes and

rules as being essential to the goal of providing a swift, efficient, and less expensive