Wash. Court of Appeals published opinion — 850318.pdf

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10 We cite to this decision pursuant to GR 14.1(b), in light of Connecticut’s repeal of

Connecticut Superior Court Rule 5-9, which had previously prohibited citation to opinions not
officially published in Connecticut.

16
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 85031-8-I/17

Armstrong, at *3.

Similarly, in Watson v. Vici Community Development Corp., No. 20-1011,

2022 WL 910155 (W.D. Okla. Mar. 28, 2022) (unpublished), the federal district

court judge therein implicitly concluded that Section 4024’s 30-day notice to

vacate paragraph applied only to notices to vacate for nonpayment of rent.11

Watson, at *10. There, the parties did not dispute that the development

corporation landlord had not provided 30 days’ notice to Watson prior to initiating

the eviction action. However, they did dispute whether the corporation’s basis for

eviction was the absence of a valid lease agreement or Watson’s nonpayment of

rent. Watson, at *10. The federal district court judge denied summary judgment

to the corporation, finding that a genuine issue of material fact existed for trial as

to the basis of the eviction therein. Watson, at *10. By so finding, the district

court judge implicitly determined that the CARES Act required 30 days’ notice

only for evictions stemming from nonpayment of rent.

Lastly, in CP Commercial Properties, LLC v. Sherman, 318 So.3d 445 (La.

Ct. App. 2d Cir. 2021), Sherman asserted that, contrary to Section 4024 of the

CARES Act, she was not provided with 30 days’ notice of the corporation’s

eviction action, notwithstanding that the action was predicated on her lease term

having ended. 318 So.3d at 446-47. The appellate court therein rejected her

argument, stating that