provide enforcement mechanisms to cities, towns, counties, or municipal corporations
including the ability to advance relocation funds to tenants who are displaced as a result
of a landlord's failure to remedy building code or health code violations and later to
collect the full amounts of these relocation funds, along with interest and penalties, from
landlords." Id. The statute's plain language and the legislature's express provision of
"funds for relocation" cannot legitimately be stretched to include emotional distress
damages.
Segura cites Rasor v. Retail Credit Co., 87 Wn.2d 516, 554 P.2d 1041 (1976), and
Martini v. Boeing Co., 137 Wn.2d 357, 971 P.2d 45 (1999), for the proposition that actual
7
No. 90088-4
damages includes damages for emotional distress. But Rasor concerned damages
available under the Fair Credit Reporting Act (FCRA), 15 U.S.C. §§ 1681-1681x, whose
purpose is '"to protect an individual from inaccurate or arbitrary information about
himself in a consumer report that is being used as a factor in determining the individual's
eligibility for credit, insurance or employment."' Rasor, 87 Wn.2d at 520 (quoting
Porter v. Talbot Perkins Children's Servs., 355 F. Supp. 174, 176 (S.D.N.Y. 1973)).
Martini addressed claims of discrimination under Washington's Law Against
Discrimination (WLAD) (chapter 49.60 RCW). See Martini, 137 Wn.2d at 366-68. The
purpose ofWLAD is to protect the "public welfare, health, and peace of the people"
because "discrimination threatens [their] rights and proper privileges." RCW 49.60.010.
Both the FCRA and WLAD guard against harm to the person. The inclusion of