Wash. Supreme Court published opinion — 901791.pdf

Citation: Wash. Supreme Court published opinion — 901791.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/901791.pdf ↗

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a separate chapter in Title 59 RCW. The legislature specifically enacted the MHLTA

separately from the Residential Landlord Tenant Act because that act did not address

the need, unique 'to mobile home owners, for stable, long-term tenancy. See 1977

FINAL LEGISLATIVE REPORT, 45th Wash. Leg. at 168.

We hold that the specific language of the MHLTA statute of frauds trumps the

general requirement that leases for over a year be acknowledged under RCW

59.04.01 0, the general tenancy statute of frauds. RCW 59.20.060 specifically

describes the requirements for complying with the statute of frauds under the MHLTA:

all rental agreements must be based on a written rental agreement that is signed by

the parties, regardless of the duration of the rental. RCW 59.20.060(1 ).

3. Purpose of the MHLTA

In addition to being supported by the plain language of RCW 59.20.040 and

.060, this reading best gives effect to the very purposes for which the MHLTA was

enacted. The legislature enacted the MHLTA, chapter 59.20 RCW, in 1977. The bill

report echoes the findings of a 1975 staff report on landlord/tenant relationship

problems in mobile home parks. See OFFICE OF PROGRAM RESEARCH, WASH. HOUSE

OF REPRESENTATIVES, STAFF REPORT ON LANDLORD-TENANT RELATIONSHIP PROBLEMS IN

MOBILE HOME PARKS (1975). The bill report specifically notes that the tenants of

manufactured/mobile home parks have a unique problem: the expense of relocating

their mobile homes if their tenancy is terminated:

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