In 1973, after years of efforts to pass comprehensive landlord-tenant law reform and
strong opposition from landlord associations, the Washington Legislature finally
passed the RLTA as Engrossed Substitute Senate Bill 2226, a compromise bill that
adopted about half of the 110 proposed amendments. 9 LAWS OF 1973, ch. 207, §§ 1-
47. The RLTA specifies numerous duties, rights, and remedies for landlords and
7
42 U.S.C. §§ 3601-3619.
8
UNIF. RESIDENTIAL LANDLORD & TENANT ACT (1972), 7B U.L.A. 275 (2018).
9
“In sum, it is hard to perceive of a more thoroughly considered piece of legislation than
the [RLTA].” State v. Schwab, 103 Wn.2d 542, 551, 693 P.2d 108 (1985). See William H. Clarke,
Washington’s Implied Warranty of Habitability: Reform or Illusion?, 14 GONZ. L. REV. 1, 5-12
(1978), for a thorough summary of the passage of the RLTA and the ways in which landlord-tenant
law developed during this period to become more just and more attuned to the realities of modern
rental housing. Once the RLTA left the legislature, the governor exercised his veto power,
attempting to excise some 14 items and sections of the RLTA—mostly in ways that would benefit
tenants, id. at 12—but this court declared all 14 item vetoes invalid, restoring the act to the
language as originally passed. Wash. Ass’n of Apt. Ass’ns v. Evans, 88 Wn.2d 563, 564 P.2d 788
(1977).
8
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Silver v. Rudeen Mgmt. Co.
No. 98024-1
tenants engaged in residential lease agreements. Ch. 59.18 RCW. When it passed,
the RLTA “represent[ed] the first meaningful change in Washington landlord-tenant
law in almost three-quarters of a century.” Survey of Washington Law: Property, 9
GONZ. L. REV. 299, 299 (1973).