# Washington CPA — key cases

Case catalog for the `wa-cpa` skill. Verify every citation against current
authority before relying on it (`wa-fact-check`); pinpoint and parallel cites
should be confirmed in the official reports.

| Case | Cite | Holding / use |
|---|---|---|
| *Hangman Ridge Training Stables, Inc. v. Safeco Title Ins. Co.* | 105 Wn.2d 778 (1986) | The **five-element** private-CPA test (unfair/deceptive act; trade or commerce; public interest; injury to business/property; causation). |
| *Klem v. Washington Mutual Bank* | 176 Wn.2d 771 (2013) | "**Unfair**" is a theory independent of "deceptive"; adopts the FTC substantial-injury / not-reasonably-avoidable / not-outweighed unfairness standard; three routes to a per se / unfair-or-deceptive act. |
| *Panag v. Farmers Ins. Co. of Wash.* | 166 Wn.2d 27 (2009) | **Deception** = capacity to deceive a substantial portion of the public (no intent, no actual deception required); **injury is distinct from damages**; investigation/response costs (e.g., consulting counsel) can be injury; a non-debtor may sue. |
| *Indoor Billboard/Washington, Inc. v. Integra Telecom of Wash., Inc.* | 162 Wn.2d 59 (2007) | **Causation** — plaintiff must prove a proximate ("but for") link between the act and the injury; no per se causation from a statutory violation. |
| *Michael v. Mosquera-Lacy* | 165 Wn.2d 595 (2009) | **Public-interest** factors for a **consumer transaction** (pattern, likelihood others solicited, regular course of business). |
| *Lightfoot v. MacDonald* | 86 Wn.2d 331 (1976) | Origin of the **public-interest** requirement — a purely private dispute is not enough. |
| *Short v. Demopolis* | 103 Wn.2d 52 (1984) | **Learned professions** — only the entrepreneurial/commercial aspects are "trade or commerce." |
| *Nordstrom, Inc. v. Tampourlos* | 107 Wn.2d 735 (1987) | **Attorney's fees** to a prevailing plaintiff are mandatory under RCW 19.86.090; discusses damages. |
| *Mason v. Mortgage America, Inc.* | 114 Wn.2d 842 (1990) | **Emotional-distress** damages may be recoverable where business/property injury is independently established. |
| *Sign-O-Lite Signs, Inc. v. DeLaurenti Florists, Inc.* | 64 Wn. App. 553 (1992) | Public-interest analysis in an essentially **private** dispute. |
| *Brown v. Old Navy, LLC* | No. 102592-1 (Wash. 2025) | CEMA subject-line violation = per se CPA violation; see `wa-cema`. |

> **NOT LEGAL ADVICE.** This catalog is a research aid. Confirm holdings,
> subsequent history, and good-law status before citing in a filing.