them rather than delivering it personally or placing a copy in the United States mail.
The RTLA addresses this requirement in RCW 59.18.280(1), which states in
relevant part:
Within twenty-one days after the termination of the rental
agreement and vacation of the premises . . . the landlord shall give
a full and specific statement of the basis for retaining any of the
deposit together with the payment of any refund due the tenant
under the terms and conditions of the rental agreement . . . .
....
(b) The landlord complies with this section if the required
statement or payment, or both, are delivered to the tenant
personally or deposited in the United States mail properly
addressed to the tenant’s last known address with first-class
postage prepaid within the twenty-one days.
(Emphasis added.) The trial court found that Mr. Hoskins complied with RCW
59.18.280 and dismissed the claim on summary judgment. Based on the plain
language of the statute and undisputed facts, we affirm.
On September 6, 2019, six days after the lease expired, 8 Hoskins sent an
e-mail to Tenants with an initial explanation of repairs and dollar amounts.
8 As noted previously, Tenants asked Hoskins, and Hoskins agreed, to extend the lease until the
end of August. While Hoskins initially identified a tenant who was willing to move into the Property
on August 24, 2019, the prospective tenant rescinded their lease with Hoskins due to (among other
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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 83734-6-I/12
Following this, on September 16, 2019, Hoskins sent Tenants an itemized
accounting of the security deposit indicating a total refund of $346.13. He then
issued payment for that amount on September 20, 2019. Payment occurred within