Right Now Heating, Cooling & Plumbing, LLC v. Estate of Gerald D. Hall

CourtCourt of Appeals of Washington
DecidedJune 4, 2026
Docket41137-1
StatusPublished

This text of Right Now Heating, Cooling & Plumbing, LLC v. Estate of Gerald D. Hall (Right Now Heating, Cooling & Plumbing, LLC v. Estate of Gerald D. Hall) 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
Right Now Heating, Cooling & Plumbing, LLC v. Estate of Gerald D. Hall, (Wash. Ct. App. 2026).

Opinion

FILED JUNE 4, 2026 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

RIGHT NOW HEATING, COOLING & ) PLUMBING, LLC, d/b/a Trademark ) No. 41137-1-III Heating & Cooling, a Delaware limited ) liability company, ) ) Respondent, ) ) PUBLISHED OPINION v. ) ) ESTATE OF GERALD D. HALL, by and ) through LEALA WALDO, as the Personal ) Representative of the Estate of Gerald D. ) Hall, ) ) Appellant. )

STAAB, C.J. — Under RCW 11.40.051(1)(b)(i)-(ii), a “reasonably ascertainable”

creditor of a decedent that does not receive actual notice of probate is allowed “24

months after the decedent’s date of death” to present its claims. On the other hand, a

creditor that is not reasonably ascertainable must present its claims “within four months

after the date of first publication of notice” to creditors.

Leala Waldo, the personal representative (PR) of the “Estate of Gerald D. Hall,”

(Estate) rejected a creditor’s claim submitted by Right Now Heating, Cooling &

Plumbing LLC, as untimely. Right Now filed a complaint against the Estate, asserting No. 41137-1-III Right Now Heating, Cooling & Plumbing, LLC v. Waldo, et al

claims for breach of contract and unjust enrichment. On summary judgment, the trial

court concluded that Right Now was a reasonably ascertainable creditor, that its claim

was timely, and that it was entitled to judgment as a matter of law on both its claims for

breach of contract and unjust enrichment.

We reverse both the trial court’s grant of summary judgment in favor of Right

Now and its denial of the Estate’s motion for summary judgment. The undisputed

evidence shows that the PR conducted a reasonable review of the decedent’s

correspondence and financial records and thus she is presumed to have exercised

reasonable diligence. In the exercise of reasonable diligence, the PR did not and could

not discover any claims by Right Now. Thus, it is presumed that Right Now is not a

reasonably ascertainable creditor. Right Now fails to raise a material issue of fact

sufficient to defeat summary judgment. Right Now has not presented clear, cogent, and

convincing evidence sufficient to overcome the presumption and demonstrate that it was

a reasonably ascertainable creditor. Because Right Now was not a reasonably

ascertainable creditor, its notice of claim was untimely.

BACKGROUND

In June 2023, prior to his passing, Gerald D. Hall entered into a home

improvement agreement with Home Depot (Agreement) for the purchase and installation

of a gas furnace. The contract defined several terms. The “Agreement” was defined, in

part, as “the Home Improvement Agreement between You and Home Depot.” Clerk’s

2 No. 41137-1-III Right Now Heating, Cooling & Plumbing, LLC v. Waldo, et al

Papers (CP) at 99. The “a Provider” was defined as “an independent contractor,

authorized by Home Depot, and its employees, agents, and subcontractors.” CP at 99.

The customer’s responsibilities included “a) Payment: You agree to pay Home Depot in

full for the Services pursuant to the terms of this Agreement.” CP at 99.

The contract price and the remaining balance were listed as “$19,335.85.” CP at

96. The Agreement further provided: “No funds should be made payable to Service

Provider; however, Service Provider may collect Customer’s payments made payable to

Home Depot.” CP at 96.

Hall provided his physical address as the “Job Site Address” and “Customer

Address”; the Agreement did not call for a mailing address. The Agreement identified

Trademark Mechanical as the Service Provider that would deliver and install the furnace.

Right Now does business as Trademark Mechanical.

Right Now delivered and installed the furnace; it then requested payment from

Hall. Hall spoke with a representative of Right Now over the phone and explained that

payment was delayed because he was waiting for Home Depot to issue him a new credit

card. According to Right Now, it sent letters requesting payment to Hall’s physical

address on July 13 and July 17, 2023. Hall passed away on July 19, 2023.

3 No. 41137-1-III Right Now Heating, Cooling & Plumbing, LLC v. Waldo, et al

Hall’s daughter opened probate proceedings and was appointed PR of the Estate.

She published a notice to creditors in a local newspaper on August 24, 2023.

Eight months after the PR first published notice to creditors, Right Now submitted

a creditor’s claim to the Estate for the total amount of the Agreement. The PR denied the

claim as untimely and Right Now filed a complaint against the Estate, alleging that Hall

had entered into a contract with Right Now as the authorized dealer for Home Depot and

breached the contract by failing to pay Right Now for services rendered. The complaint

also claimed damages under a theory of unjust enrichment.

Before the close of discovery, Right Now moved for summary judgment on its

claims. The Estate opposed the motion and requested the court grant summary judgment

in favor of the Estate, dismissing Right Now’s claims. The PR submitted a declaration to

establish due diligence in searching and reviewing the decedent’s correspondence:

[P]osting legal notice of my father’s death in newspapers, contacting my father’s cell phone provider, paying the bill and cancelling services, contacting his credit cards which were discovered either via mail or found in his personal possessions. These bills were resolved as well, and those accounts were subsequently cancelled or closed. [I] sent Notice to creditors to nine different companies, including Home Depot Credit Services.[1] I also contacted utility companies to pay any remaining balances and cancel services. I had my father’s mail forwarded to my North Carolina address as stated above and responded to any and all correspondence received on behalf of my father. If anything from “Right Now” or

1 The Estate argues that Home Depot had notice of probate and failed to bring a creditor’s claim. However, it appears Home Depot Credit Services was identified and notified based on the decedent’s credit card statement; Home Depot U.S.A., Inc. was the entity that was party to the Agreement.

4 No. 41137-1-III Right Now Heating, Cooling & Plumbing, LLC v. Waldo, et al

“Trademark Mechanical” had been in his papers to be found, I would have included them in the mailings.

CP at 116-17.

The PR also explained that she had not checked Hall’s mailbox for mail because

Hall used a post office box and had not received mail at his physical address for many

years prior to his passing. She further declared that she was unaware of the Agreement

until she received the documents from Right Now after it submitted its claim.

Right Now submitted evidence of its efforts to collect payment and declared that

the letters it sent the week prior to Hall’s passing were not returned as undeliverable.

Following a hearing, the trial court granted Right Now’s motion for summary

judgment. The court awarded Right Now the amount owed under the Agreement; it also

awarded costs, attorney fees, and pre- and post-judgment interest.

The Estate appeals.

ANALYSIS

The Estate contends the court erred by granting summary judgment in favor of

Right Now because its claims were time barred and Right Now failed to present clear,

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Right Now Heating, Cooling & Plumbing, LLC v. Estate of Gerald D. Hall, Counsel Stack Legal Research, https://law.counselstack.com/opinion/right-now-heating-cooling-plumbing-llc-v-estate-of-gerald-d-hall-washctapp-2026.