Wash. Court of Appeals published opinion — 389189_pub.pdf

Citation: Wash. Court of Appeals published opinion — 389189_pub.pdf
Jurisdiction: Washington (state)
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conclusion reached” by K&H. Hous. Auth. v. Pyrtle, 167 Ga. App. 181, 182, 306 S.E.2d 9

(1983); see Swords to Plowshares v. Smith, 294 F. Supp. 2d 1067, 1072 (N.D. Cal. 2002)

(“[N]otice must enable [a] tenant to prepare a defense or rebuttal evidence . . . .”). 3

We disagree with Ms. Daniels that K&H should have been clearer regarding the

four bases for eviction set forth in RCW 59.18.650(2)(c). A fair reading of the notice is

that K&H believed Ms. Daniels may have violated any of the four statutory clauses, while

recognizing that only one such violation would be necessary to terminate her tenancy.

Moreover, the real question regarding notice is whether Ms. Daniels understood the

3
The “specificity” requirement in RCW 59.18.650(6)(b), effective since May
2021, has not yet been interpreted by an appellate court. Ms. Daniels points out that
federal regulations governing evictions from federally subsidized projects impose a
comparable requirement. See 24 C.F.R. § 247.4(a)(2) (“The landlord’s determination
to terminate the tenancy shall . . . state the reasons for the landlord’s action with enough
specificity so as to enable the tenant to prepare a defense . . . .” (emphasis added)).
Given the scarcity of Washington authority on point, we may look to foreign cases
interpreting such federal regulations, such as Pyrtle and Swords to Plowshares, for
guidance. See In re Welfare of Colyer, 99 Wn.2d 114, 119, 660 P.2d 738 (1983).

17
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 38918-9-III
Kiemle & Hagood Co. v. Daniels

factual allegations against her. See Tacoma Rescue Mission v. Stewart, 155 Wn. App.

250, 255, 228 P.3d 1289 (2010); see also RCW 59.18.650(6)(b) (requiring landlords