Raymond Moss v. Clark County Title

CourtCourt of Appeals of Washington
DecidedMay 12, 2026
Docket60721-2
StatusUnpublished

This text of Raymond Moss v. Clark County Title (Raymond Moss v. Clark County Title) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Raymond Moss v. Clark County Title, (Wash. Ct. App. 2026).

Opinion

Filed Washington State Court of Appeals Division Two

May 12, 2026 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II RAYMOND MOSS, No. 60721-2-II

Appellant,

v.

CLARK COUNTY TITLE, UNPUBLISHED OPINION

Respondent.

GLASGOW, J.—The sale of Raymond Moss’ property closed in March 2016. It is undisputed

that in August 2017, Moss received notice that a U.S. Department of Housing and Urban

Development (HUD) mortgage loan on the property remained outstanding. Over six years later,

Moss filed a complaint against Clark County Title, who Moss had contracted with to provide

escrow and closing services on the 2016 property sale. Clark County Title moved for summary

judgment dismissal of all Moss’ claims, arguing that the statutes of limitations had all expired. The

trial court agreed and granted summary judgment. Moss appeals, arguing that the discovery rule

applies and his claims are not barred by the statutes of limitation, he is entitled to equitable tolling

of the statutes of limitation, or equitable estoppel requires reversal. We disagree and affirm.

FACTS

In 2016, Moss contracted with Clark County Title to provide escrow services to close on

the sale of his property. At the time, Moss had a primary mortgage on the property as well as a

HUD loan. The property sale closed on March 7, 2016. The proceeds of the sale totaling $324,980

were used to pay off the primary mortgage and associated closing costs. After paying off the No. 60721-2-II

primary mortgage and associated closing costs, a negative balance of $3,418.47 remained and

Moss had to provide additional funds to sell the property. The HUD loan was not discharged.

In August 2017, Moss received a notice from a debt collector stating that the HUD

mortgage loan remained outstanding and Moss owed $63,615.78 plus fees and interest. Moss

contacted an attorney who contacted Clark County Title about addressing the issue. As a result of

the delinquent HUD loan, Moss claims to have suffered a negative impact on his credit score,

resulting in high interest rate loans on an RV and vehicle purchase in 2017 and higher interest rates

on credit cards opened in 2017. Garnishment of Moss’ wages began in 2022.

On March 4, 2024, more than six years after he received notice from the debt collector that

his HUD loan remained outstanding, Moss filed a complaint against Clark County Title for breach

of contract, violation of the Consumer Protection Act, ch. 19.86 RCW and declaratory relief. Clark

County Title moved for summary judgment dismissal of all Moss’ claims, arguing that the statutes

of limitations on all claims had expired.

Moss opposed the motion for summary judgment. Moss argued that the discovery rule

applied to his breach of contract claim or, alternatively, the continuing violation doctrine extended

the expiration of the statute of limitations. Moss contended that Clark County Title’s failure to

properly discharge the HUD loan was a continuing breach of contract. Moss also argued that the

statute of limitations should be equitably tolled because Clark County Title’s own actions

prevented the timely discovery of the breach.

As to the Consumer Protection Act claim, Moss argued that the discovery rule applied to

extend the statute of limitations. He contended he could not reasonably have learned that Clark

County Title had failed to obtain a payoff for the HUD loan until 2017 and that the ongoing

2 No. 60721-2-II

garnishment of his wages further extended the limitations period under the continuing violation

theory.

In his declaration, Moss stated that he received notice that the HUD loan was delinquent

in August 2017 and immediately contacted an attorney who contacted Clark County Title. Moss

recounted the various negative impacts the HUD loan had on his credit, including the imposition

of higher interest rates when he purchased an RV and car and when he applied for credit cards in

2017, as well as garnishment of his wages.

The trial court granted Clark County Title’s motion for summary judgment and dismissed

all Moss’ claims with prejudice. 1

Moss appeals.

ANALYSIS

Moss argues that the trial court erred by granting summary judgment. We disagree.

We review a trial court’s dismissal on summary judgment de novo, performing the same

inquiry as the trial court. Mackey v. Home Depot USA, Inc., 12 Wn. App. 2d 557, 569, 459 P.3d

371 (2020). Summary judgment is appropriate only “if the pleadings, depositions, answers to

interrogatories, and admissions on file, together with the affidavits . . . show that there is no genuine

issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”

CR 56(c). “‘A material fact is one upon which the outcome of the litigation depends.’” Mattingly

v. Palmer Ridge Homes, LLC, 157 Wn. App. 376, 387, 238 P.3d 505 (2010) (quoting Balise v.

Underwood, 62 Wn.2d 195, 199, 381 P.2d 966 (1963)). A genuine issue of material fact exists

1 Although Moss raised equitable estoppel in a motion for reconsideration, he ultimately struck his own motion.

3 No. 60721-2-II

where “reasonable minds could disagree on the facts controlling the outcome of the case.” Mackey,

12 Wn. App. 2d at 569.

“When determining whether an issue of material fact exists,” we “must construe all facts

and inferences in favor of the nonmoving party.” Ranger Ins. Co. v. Pierce County, 164 Wn.2d

545, 552, 192 P.3d 886 (2008). On summary judgment, “a nonmoving party’s declaration must be

taken as true and can create a genuine issue of material fact even if it is ‘self-serving.’” Mackey,

12 Wn. App. 2d at 575 (quoting Reagan v. Newton, 7 Wn. App. 2d 781, 806, 436 P.3d 411 (2019)).

I. STATUTES OF LIMITATIONS

Whether a case was filed within the statute of limitations period is a question of law which

we also review de novo. Cortez-Kloehn v. Morrison, 162 Wn. App. 166, 172-73, 252 P.3d 909

(2011). The defendant bears the burden to prove that the statute of limitations bars a claim. Kiona

Park Ests. v. Dehls, 18 Wn. App. 2d 328, 336, 491 P.3d 247 (2021). Statutes of limitations begin

to run when a cause of action accrues. 1000 Va. Ltd. P'ship v. Vertecs Corp., 158 Wn.2d 566, 575,

146 P.3d 423 (2006). A cause of action typically accrues “when the party has the right to apply to

a court for relief.” Id.

The statute of limitations for a breach of contract claim is six years. RCW 4.16.040. The

statute of limitations for a violation of the Consumer Protection Act is four years. RCW 19.86.120.

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