The Doctrine of Foakes v. Beer in Washington

Application of the rule to defeat discharge of a money debt by payment of a part, received by the creditor as full satisfaction, has been severely criticized. In this situation, two jurisdictions have abandoned the rule by decision, others by statute. The Washington decisions on the problem are not harmonious. 10 Although our court has followed Foakes v. Beer in a variety of situations, there are a number of money debt cases which circumvent the rule.