§24.3 Historical Development

• Jurisdiction: Washington

§24.3 HISTORICAL DEVELOPMENT

CR 24 was adopted in 1967. It is based on Fed. R. Civ. P. 24 and has not been amended. It liberalized both permissive intervention and intervention of right.

Prior to the adoption of CR 24, permissive intervention was allowed only before trial, as required by former RCW 4.08.190 (repealed 1984). CR 24 superseded that requirement by allowing intervention at any time during a judicial proceeding, Sutton v. Hirvonen,113 Wn.2d 1, 775 P.2d 448 (1989), including posttrial proceedings. Kreidler v. Eikenberry,111 Wn.2d 828, 766 P.2d 438 (1989); Olver v. Fowler,131 Wn.App. 135, 139, 126P.3d69 (2006), aff'd,161 Wn.2d 655, 168P.3d348 (2007); Columbia Gorge Audubon Soc'y v. Klickitat Cnty., 98 Wn.App. 618, 623-24, 989P.2d1260 (1999)...