a city ordinance, containing language similar to RCW 59.18.625, which prohibited
landlords from charging interest on past due rent, was preempted by RCW 19.52.010.
Id. at 443. Furthermore, Mr. Christensen asserts that, in passing RCW 59.18.625, the
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No. 39271-6-III
Heston v. Christensen
legislature addressed conflicts of law, yet failed to include any reference to RCW
19.52.010. See LAWS OF 2021, ch. 115, § 20.
In the event of a conflict between two statutes, the court looks to a variety of
factors to determine which law controls. As a general rule, a later-adopted statute is
given preference over a conflicting statute. Ass’n of Wash. Bus. v. Dep’t of Revenue,
155 Wn.2d 430, 449, 120 P.3d 46 (2005). Further, “[u]nder the principle of statutory
construction, the specific statute prevails over a general statute.” O.S.T. v. Regence
Blueshield, 181 Wn.2d 691, 701, 335 P.3d 416 (2014).
Here, the statute that barred the imposition of late fees and other charges,
RCW 59.18.625, became effective on April 22, 2021, while the current version of
RCW 19.52.010 became effective on July 28, 2019. See LAWS OF 2021, ch. 115;
LAWS OF 2019, ch. 227. Moreover, RCW 59.18.625 was passed with the specific intent
of alleviating some of the burdens renters faced during the public health crisis brought on
during the COVID-19 pandemic, while RCW 19.52.010 merely lays out exceptions to
prejudgment interest on consumer leases and does not specifically address the issue of
property. See LAWS OF 2021, ch. 115. RCW 59.18.625 is both the later-adopted statute
as well as the statute specific to the issues raised in this appeal. Accordingly, as it