emotional distress damages in those cases is not surprising, as such provision comports
with the purpose and protections afforded by the statutes in question. But no similar
purpose is present in this case. Here, the text of the statute, as discussed above, attests
that the legislature is concerned only with return of a tenant's money and assisting the
tenant in getting relocated, not in providing redress for a personal injury or protecting
against harm to the person. There is no similarity to the types of situations presented in
Rasor and Martini, which involved different statutes with different language and different
purposes.
For the same reason, Segura's citation to Ellingson v. Spokane Mortgage Co., 19
Wn. App. 48, 573 P.2d 389 (1978), and Conrad v. A/derwood Manor, 119 Wn. App. 275,
8
No. 90088-4
78 P.3d 177 (2003), as support is also unavailing. Ellingson addressed claims of
discrimination under the WLAD, and Conrad addressed claims under the abuse of ·
vulnerable adults statute (chapter 74.34 RCW). See Ellingson, 19 Wn. App. at 54;
Conrad, 119 Wn. App. at 280. These cases too are distinguishable, as they addressed
statutes and circumstances that are not present here.
We have never adopted a single definition of the term "actual damages." Indeed,
in the appropriate case, we have limited "actual damages" to include only recovery for
pecuniary harm. For example, the Washington Consumer Protection Act (CPA) allows a
person harmed under the statute "to recover the actual damages sustained by him or her
... together with the costs of the suit, including a reasonable attorney's fee." RCW
19.86.090. As in this case, the statute included language allowing recovery for "actual