10
This interpretation of the JCEO does not undermine the summary nature of
unlawful detainer proceedings. See Amicus Curiae Mem. of Rental Hous. Ass'n of Wash.
at 8 (noting that show cause hearings are "designed to be more efficient than trials"); see
also Christensen, 162 Wn.2d at 375-76 (the purpose of the unlawful detainer statute "is to
provide a landlord with a speedy, efficient procedure by which to obtain possession of the
premises after a breach by the tenant"). It simply recognizes that the JCEO does not
fundamentally alter such proceedings.
-18-
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Faciszewski, et al. v. Brown, et al., 92978-5
would leave a tenant with a lesser ability to defend against an unlawful detainer when
a landlord files a certification. Moreover, the remedy provisions of SMC
22.206.160(C)(6) and (7) do not rest on whether the landlord can prove just cause in
an action to terminate a tenancy. Instead, they provide a separate cause of action if,
after an eviction or attempted eviction on certain grounds, the landlord does not
fulfill or carry out the stated reason. With respect to the eviction action itself, two
provisions of the JCEO clearly provide that the landlord must have just cause, SMC
22.206.160(C)(l), and that the lack of just cause can be raised by the tenant
defending against the action, SMC 22.206.160(C)(5).
We hold that Seattle's JCEO does not restrict the tenant's opportunity to
contest the truthfulness of the landlord's certification at an unlawful detainer show
cause hearing. It follows that a judicial officer at the show cause hearing may accept
relevant evidence ofjust cause and the landlord's certification is not dispositive. The