(“Because it gave deficient notice, the Housing Authority could not prove a cause
of action for unlawful detainer.”). Accordingly, “a trial court cannot grant relief in
an unlawful detainer action when a landlord has failed to comply with the relevant
[notice requirement].” Henry-Levingston, 196 Wn. App. at 699. When a landlord
files an unlawful detainer action after providing inadequate notice, which includes
failing to clearly set forth the requisite period to cure the alleged default, the
action must be dismissed. See, e.g., Heuft, 141 Wn. App. at 633 (vacating the
judgment entered in an unlawful detainer action because the landlord failed to
provide the cure period provided by the lease); Cmty. Invs., Ltd., 36 Wn. App. at
37-38 (affirming the trial court’s dismissal of an unlawful detainer action because
the landlord did not provide the required 20 days to cure the default).
B
Here, Sherwood Auburn served Pinzon and Mendez with two notices—a
14-day pay or vacate notice pursuant to RCW 59.12.030(3), and an additional
notice entitled “30-DAY NOTICE (CARES Act)” stating that, “if a court so
order[ed],” Pinzon and Mendez could be “required to vacate the residential unit in
not less than 30 days” from the date of the notice. These notices did not
unequivocally inform Pinzon and Mendez that, pursuant to the CARES Act, they
had 30 days from the date of notice to cure the alleged nonpayment of rent or to
vacate the premises. Notice must be “sufficiently particular and certain so as not
to deceive or mislead.” Heuft, 141 Wn. App. at 632. Thus, when the notice
provided does not accurately convey the correct time period to cure or vacate,
the notice is not sufficient. Heuft, 141 Wn. App. at 633 (landlord provided a