Wash. Supreme Court published opinion — 901791.pdf

the statute of frauds established by RCW 59.20.060, requiring a writing but not an

acknowledgement, regulates and determines this case.

2. The specific language of RCW 59.20.060 controls

Principles of statutory interpretation also support the conclusion that we apply

the MHLTA statute of frauds to the MHLTA, instead of the earlier enacted and more

general tenancy statute of frauds. A general statutory provision normally yields to a

more specific statutory provision. Waste Mgmt. of Seattle, Inc. v. Utils. & Transp.

Comm'n, 123 Wn.2d 621, 629-30, 869 P.2d 1034 (1994). "To resolve apparent

conflicts between statutes, courts generally give preference to the more specific and

more recently enacted statute." Tunstall v. Bergeson, 141 Wn.2d 201, 211, 5 P.3d 691

(2000).

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

RCW 59.04.010 modifies RCW 64.04.010 and is the general statute of frauds

governing tenancies. These statutes, read together, require tenancies for more than

a year to be in writing and to be acknowledged. They have been in effect since the

territorial days. Neither statute expressly incorporates mobile homes or any other

specific type of tenancy.

In contrast, RCW 59.20.060 is a statute of frauds that relates specifically to

rental agreements for mobile home lots. Mobile home space tenancies "shall be based

upon a written rental agreement [that is] signed by the parties." RCW 59.20.060(1 ).

This is the requirement, regardless of the duration of the tenancy. /d. Additionally, as

discussed in Part 111.8.1 of this opinion, supra, RCW 59.20.040 of the MHLTAexplicitly

distinguishes between the rules governing the rental of mobile home lots from the