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Rule 23.2.Actions relating to unincorporated associations

Group 4: Parties · Last amended July 1, 1967 · Last verified July 13, 2026

In one sentenceRule 23.2 allows a lawsuit by or against an unincorporated association to be brought through named representative members, borrowing Rule 23's adequacy standard and its rules for court orders, dismissal, and settlement.

Full Text of Rule 23.2

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An action brought by or against the members of an unincorporated association as a class by naming certain members as representative parties may be maintained only if it appears that the representative parties will fairly and adequately protect the interests of the association and its members. In the conduct of the action the court may make appropriate orders corresponding with those described in rule 23(d), and the procedure for dismissal or compromise of the action shall correspond with that provided in rule 23(e).

Amendment History

Prior: RPPP Rule 23(b) part. Adopted May 5, 1967, effective July 1, 1967.

Plain-English Summary

Unincorporated associations — clubs, unions, and similar groups without corporate status — don't always fit neatly into a lawsuit as a single named party. Rule 23.2 lets litigation proceed by or against the association's members as a class, represented by a few named members, rather than requiring everyone to be joined individually.

That shortcut comes with one condition: the representative members have to be capable of adequately protecting the interests of the association and its members as a whole. If they can't, the representative format isn't available. Once a case does proceed this way, the court borrows the same tools it would use in a full class action — the case-management orders described in Rule 23(d), and the requirement in Rule 23(e) that dismissal or settlement needs court approval.

Frequently Asked Questions

Why would a lawsuit against an unincorporated association use representative members?

Because the association itself may not be a legal entity capable of suing or being sued as a single party, Rule 23.2 lets the case proceed against, or on behalf of, named members standing in for the whole group.

What has to be true before a court allows this representative format?

The representative parties must be able to adequately protect the interests of the association and its members — the same core concern that runs through Rule 23's adequacy requirement for class representatives.

Which parts of Rule 23 apply to an action under Rule 23.2?

The court's authority to issue case-management orders under Rule 23(d), and the requirement under Rule 23(e) that the action can't be dismissed or settled without court approval.

Is a suit under Rule 23.2 the same as a class action under Rule 23?

No. It borrows specific procedural tools from Rule 23 but is its own narrower mechanism, built for the particular problem of litigating by or against an unincorporated group.

Source & verification. Rule text and amendment history are reproduced verbatim from the Washington Superior Court Civil Rules, adopted by the Supreme Court of Washington. Last verified July 13, 2026. · Official source
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