Seamans v. Walgren
In Seamans v. Walgren, 82 Wn.2d 771, 775, 514 P.2d 166 (1973), the defendant was a member of the Legislature, and the statute of limitations was tolled for the period of time the Legislature was in session and a stated period before the legislative session, because a state legislator is immune from service of process under the state constitution.
However, when the period of immunity was added to the limitations period, both the filing of the complaint and service of process occurred within the limitations period.
As the court noted, RCW 4.16.170 therefore did not apply. Seamans, 82 Wn.2d at 775.