Washington Supreme Court
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Riss v. Angel
Riss v. Angel, 131 Wn.2d 612, 934 P.2d 669 (1997)
Holding
The Washington Supreme Court held that HOA assessment liens created under CC&Rs are equitable liens that attach to the property and have priority established by the recording date of the declaration. The lien runs with the land and is enforceable against subsequent purchasers. This case is foundational for understanding assessment lien priority in Washington.
Treatment Notes
Washington Supreme Court decision on assessment lien priority. Foundational for title company due diligence and resale certificate disclosures about outstanding liens. Impacts lien priority analysis in RC generation.
Statutes Interpreted
Legal Topics
Case record last verified May 19, 2026.
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