The Washington State Supreme Court issued an opinion February 12, 2026, in *Chandrruangphen v. City of Sammamish* addressing critical procedural requirements under the Land Use Petition Act (LUPA) that affect how property disputes are litigated across the state. The case, numbered 103789-9, involves respondent Wanthida Chandrruangphen and petitioner City of Sammamish, with Daniel Bloom as an intervenor/petitioner.
The court's opinion, authored by Justice Mary Yu serving as a justice pro tempore, focuses on two key legal questions that have implications for land use litigation throughout Washington. The first issue concerns whether service on a nonstatutorily designated city employee strictly complies with applicable service statutes when serving a LUPA petition on a municipality. The second addresses whether LUPA's three-day tolling provision, which applies to "mailed" land use decisions, also extends to decisions transmitted solely by email.
Under Washington law, the service statute designates specific individuals who may accept personal service on behalf of a municipality, as outlined in RCW 4.28.080(2). The court examined whether strict compliance with these statutory designations is required when serving municipalities with LUPA petitions, or whether service on other city employees might suffice.
The Land Use Petition Act establishes strict timelines for accomplishing service, making the proper identification of authorized recipients crucial for property owners and developers seeking to challenge municipal land use decisions. LUPA provides the exclusive judicial remedy for challenging land use decisions made by local governments, making procedural compliance essential for preserving appeal rights.
The case also addressed the evolution of municipal communications in the digital age. As local governments increasingly rely on email rather than traditional mail for transmitting land use decisions, questions arise about how existing statutory provisions apply to electronic communications. LUPA's three-day tolling provision was originally drafted with postal mail in mind, but the court examined whether this provision extends to email transmissions.
This procedural question has practical significance for calculating appeal deadlines. Under LUPA, petitioners typically have 21 days from the date a land use decision is issued to file their petition. The three-day tolling provision can extend this deadline when decisions are mailed, but its application to email transmission had been unclear.
The dispute between Chandrruangphen and the City of Sammamish represents the type of land use conflicts that regularly arise across Washington's growing municipalities. Property owners and developers frequently challenge local zoning decisions, permit denials, and other land use determinations through LUPA proceedings. The procedural requirements governing these challenges directly affect the ability of parties to access judicial review.
Sammamish, located in King County, is among Washington's municipalities that have faced increasing development pressure and associated land use disputes. The city's involvement as petitioner suggests the municipal government sought Supreme Court review of a lower court decision that may have been unfavorable to its position.
The presence of Daniel Bloom as an intervenor/petitioner indicates that third parties with interests in the underlying land use dispute also sought Supreme Court review. LUPA proceedings often involve multiple parties, including neighboring property owners, developers, and advocacy groups with varying interests in proposed developments or zoning changes.
Justice Yu's opinion addresses fundamental questions about how Washington's land use appeal system functions in practice. The court's interpretation of service requirements will guide attorneys, property owners, and municipalities in ensuring proper compliance with LUPA procedures. Similarly, the ruling on email transmission and tolling provisions will affect how appeal deadlines are calculated in an increasingly digital environment.
The Supreme Court's resolution of these procedural questions provides necessary clarity for the land use bar and helps ensure that technical service requirements don't prevent substantive review of municipal land use decisions. Property rights advocates have long emphasized the importance of maintaining accessible appeal processes for challenging local government decisions that affect private property.
For municipalities, the decision clarifies their obligations regarding proper service acceptance and communication practices. Cities must ensure that designated officials are available to accept service and that their communication methods regarding land use decisions comply with statutory requirements.
The ruling's impact extends beyond the immediate parties to affect land use practice statewide. Washington's growth and development pressures make land use disputes increasingly common, making clear procedural rules essential for efficient dispute resolution. The court's guidance on service requirements and electronic communications will influence how these disputes are initiated and processed.
Legal practitioners handling land use matters will need to review their service practices and deadline calculations in light of the Supreme Court's interpretation of these statutory requirements. The decision reinforces the importance of strict procedural compliance in LUPA proceedings while adapting traditional requirements to modern communication methods.