Edison Oyster Co. v. Pioneer Oyster Co
In Edison Oyster Co. v. Pioneer Oyster Co., 22 Wn.2d 616, 626-27, 157 P.2d 302 (1945), an oyster company had a right of action in replevin to recover its oysters immediately upon discovery that the oysters had drifted onto adjoining tideland; before filing suit, however, the oyster company needed to first make a demand upon the adjoining tideland owner for return of the oysters. 22 Wn.2d at 626.
In Young, the plaintiffs had a right of action against a municipal corporation immediately after an accident involving a passenger bus owned and operated by the city; but before filing suit, the plaintiffs needed to first present their claim to the city. 30 Wn.2d at 359-60.
In both of these cases, there was no question regarding when the plaintiffs' causes of action had accrued.
Rather, the issue was whether the plaintiffs' delays in performing the procedural prerequisites to filing suit could extend the statute of limitations. Young, 30 Wn.2d at 361-64; Edison, 22 Wn.2d at 626-27.