The Washington Court of Appeals has reversed a trial court's decision to cancel a lis pendens filed by Elizabeth Parman in her ongoing dispute with the estate of her former mother-in-law, Ruth Parman, and her ex-husband, Shawn Parman. This ruling, issued on July 14, 2026, affects Elizabeth's claim for unjust enrichment related to a property known as the Renata Lane property, which she argues she has a rightful interest in due to her financial contributions over the years.
The case, Elizabeth Parman v. Estate of Ruth Parman and Shawn Parman, No. 60735-2-II, centers around Elizabeth's claims that she was unjustly enriched by the Parmans after she invested significant money into the property, which she believed would ultimately be inherited by her and her former husband. The court's decision to reinstate the lis pendens is significant as it allows Elizabeth to maintain a legal claim over the property while the case is ongoing.
Background
Elizabeth Parman filed her original action against Shawn and Ruth Parman in 2018, alleging unjust enrichment among other claims. The dispute arose after Elizabeth and Shawn, who were married at the time, quitclaimed the Renata Lane property to Shawn's parents, Ruth and Robert Parman, in 2000. Elizabeth purchased the property in 1997 for $117,000 and subsequently invested an additional $143,000 into it with plans to develop a horse farm.
After Elizabeth and Shawn divorced in 2017, Ruth revoked her will, which had previously promised Elizabeth an inheritance from the property, leaving it solely to Shawn. Elizabeth argued that her contributions to the property should entitle her to a share of its value, prompting her to file a notice of lis pendens in 2019 to assert her claim against the property.
The Parmans contested the lis pendens multiple times, but the trial court initially denied their motions to cancel it. However, after a series of appeals and remands, the trial court ultimately granted the Parmans' third motion to cancel the lis pendens, leading Elizabeth to appeal that decision.
The Ruling
The Washington Court of Appeals ruled in favor of Elizabeth, stating that the trial court erred in cancelling the lis pendens. The court found that Elizabeth's unjust enrichment claim, which sought an equitable lien based on her financial contributions to the property, indeed affected the title to real property as required under Washington law.
The court stated, "A claim for unjust enrichment, that seeks an equitable lien where the plaintiff’s claim is based on their resources being used to enhance the value of the real property at issue, is an action that affects title to real property as required under RCW 4.28.320 and RCW 4.28.328(2)."
The judges on the panel included Chief Judge Veljacic, Judge Maxa, and Judge Che. They concluded that Elizabeth was entitled to maintain her lis pendens while her unjust enrichment claim was being resolved.
Impact
This ruling has significant implications for Elizabeth's case and similar cases involving unjust enrichment claims tied to real property. By reinstating the lis pendens, the court has allowed Elizabeth to continue asserting her claim against the property, which could ultimately affect its ownership and value.
The decision clarifies that an unjust enrichment claim that has a sufficient connection to real property can support a lis pendens, which serves as a notice to potential buyers or lenders that the property is subject to ongoing litigation. This ruling may set a precedent for future cases where individuals seek to assert claims over properties based on contributions made without formal ownership.
What's Next
With the reinstatement of the lis pendens, Elizabeth will continue her legal battle against the Parmans regarding her unjust enrichment claim. The case will proceed in the lower court, and it remains to be seen whether the Parmans will seek further appeals or if any related cases will emerge as a result of this ruling.