Wash. Supreme Court published opinion — 901791.pdf

contract creating or evidencing any encumbrance upon real estate, shall· be by deed .... "
Under RCW 64.04.020, "[e]very deed shall be in writing, si.gned by the party bound thereby,
and acknowledged by the party before some person authorized by this act to take
acknowledgement of deeds." (Reviser's note omitted.)
9 A "tenancy from year to year" is a periodic tenancy that automatically renews for a year

unless terminated at the end of the year by notice. BLACK'S, supra, at 1694. The default lease
under the MHLTA is a tenancy from year to year. RCW 59.20.090(1).

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Western Plaza, LLC v. Tison, No. 90179-1

that applies to manufactured home lot leases. First, the plain language of RCW

59.20.040 supports this conclusion:

This chapter shall regulate and determine legal rights, remedies, and
obligations arising from any rental agreement between a landlord and a
tenant regarding a mobile home lot and including specified amenities
. '

within the mobile home park, mobile home park cooperative, or mobile
home park subdivision, where the tenant has no ownership interest in
the property or in the association which owns the property, whose uses
are referred to as a part of the· rent structure paid by the tenant. ...
Rentals of mobile homes, manufactured homes, or park models
themselves are governed by the residential landlord-tenant act, chapter
59.18 RCW.

This action was brought to enforce or determine "legal rights, remedies, and

obligations arising from [a] rental agreement between a landlord and a tenant

regarding a mobile home lot." RCW 59.20.040 tells us that "[t]his chapter"-the

MHLTA-regulates and determines these rights. The conclusion is inescapable that