RCW 40.16.030 Interpretation
In State v. Price, 94 Wn.2d 810, 620 P.2d 994 (1980), the Court considered the analysis of other jurisdictions.
The Court first rejected the extremely limited analysis of the California courts, which defined an instrument as "'an agreement expressed in writing, signed, and delivered by one person to another, transferring the title to or creating a lien on real property, or giving a right to a debt or duty.'" Id. at 817
The Court then rejected the broad definition of the Arizona Supreme Court, which held that any document required or permitted by a state government agency is sufficiently important to be included within the scope of the statute. Price, 94 Wn.2d at 818.
"We are not persuaded by either the California or Arizona analysis. . . . We do not believe the legislature intended the substantial penalties of RCW 40.16.030 to be universally applicable whenever a piece of paper may be filed in a public office." Price, 94 Wn.2d at 818.
In Price, the Court found that RCW 40.16.030 requires that a document be "required or permitted by law, statute or valid regulation." Price, 94 Wn.2d at 819