The case of State ex Rel. Long v. McLeod is a pivotal decision in Washington law that clarifies whether corporations can act as plaintiffs in small claims courts. This 1972 case examines the balance between the simplicity intended by small claims court proceedings and the constitutional rights of corporations.
Case Background
In this case, Relator Long and Intervenor Nitz sought a writ of prohibition to prevent Justice Court Judge Murray McLeod from allowing corporations to sue in small claims court. They argued that the Small Claims Act, specifically RCW 12.40.080, was intended to provide a simple forum for individuals to resolve minor disputes without the need for legal representation, not for corporations that might leverage their resources to dominate proceedings.
The appellants contended that allowing corporations to sue in small claims courts would undermine the legislative intent of creating a straightforward, low-cost avenue for individuals. They feared that corporations could exploit this system, creating an imbalance that would disadvantage less experienced individual defendants.
Court’s Decision
The Washington Court of Appeals rejected the appellants’ arguments, emphasizing that the Washington State Constitution does not distinguish between corporations and individuals regarding access to courts. Article 12, Section 5 of the Washington Constitution clearly states that all corporations have the right to sue and be sued in all courts, just as natural persons do.
The court found no legislative intent within RCW 12.40—the Small Claims Act—to exclude corporations from filing suits in small claims courts. The court cited the California case Prudential Ins. Co. of America v. Small Claims Court, which supported the idea that corporations, like individuals, can be plaintiffs in small claims court through non-attorney representatives, even though the presence of attorneys is generally prohibited in such proceedings.
The decision affirms that corporations in Washington State have the constitutional right to sue in small claims court, ensuring equal access to this legal avenue for all entities, whether corporate or individual.
Key Takeaways
- Constitutional Rights: Corporations in Washington have the same rights as individuals to sue in all courts, including small claims courts, under Article 12, Section 5 of the Washington Constitution.
- Small Claims Court: The Washington Small Claims Act does not exclude corporations from participating as plaintiffs in small claims courts, even though attorneys are generally not allowed.
- Legal Representation: Corporations may represent themselves through non-attorney representatives in small claims court, maintaining the simplicity and accessibility intended by the Small Claims Act.
For more detailed information, you can review the full text of the case here.
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