interpretation. "Our fundamental purpose in construing statutes is to ascertain and
carry out the intent of the legislature." In re Marriage of Schneider, 1'73 Wn.2d 353,
363, 268 P.3d 215 (2011 ). We determine legislative intent from the plain language
enacted by the legislature, considering the text of the provision in question, the context
of the statute in which the provision is found, related provisions, amendments to the
provision, and the statutory scheme as a whole. Campbell & Gwinn, LLC, 146 Wn.2d
at 9-12.
A. Summary of Analysis
There are two statutes of frauds that are potentially applicable to the Tison
lease: RCW 59.04.01 0, titled "Tenancies[6l from year to year abolished except under
written contract"; and RCW 59.20.060, titled "Rental agreements-Required
contents-Prohibited provisions." 7 (Boldface omitted.) Though neither is called a
statute of frauds, these statutes govern the formal requirements for creating a valid
lease. In deciding which of these statutes of frauds to apply to the MHLTA, we
6
A "tenancy" is "[t]he possession or occupancy of land under a lease." BLACK's LAW
DICTIONARY 1694 (10th ed. 2014).
7 There are two additional statutes of frauds governing interests in real estate: RCW
59.18.21 0, the residential landlord-tenant statute of frauds, and RCW 64.04.01 0, the general
real estate statute of frauds. The Residential Landlord-Tenant Act of 1973, chapter 59.18
RCW, governs rentals of mobile homes, manufactured homes, or park models themselves; it
does not govern tenancies regarding a mobile home lot separate from a mobile home itself.
RCW 59.20.040. As discussed in greater detail below, RCW 59.04.010 creates an exception
to, and takes the place of, RCW 64.04.01 0 for tenancies.