Wash. Court of Appeals published opinion — D2 47696-7-II Published Opinion.pdf

could not file an unlawful detainer action under RCW 59.12.030(1) when the landlord

unilaterally terminated the lease before the end of the lease term. Id.

But unlike in FPA Crescent, Housing Kitsap did not terminate the lease before the end of

the specified lease term. As stated above, the term of Kimbra’s lease expired on December 31,

2014. Housing Kitsap’s termination letter indicated that Kimbra’s lease was terminated on that

date.

We hold that Kimbra’s lease had a specified term that expired on December 31, 2014,

unless it automatically renewed as discussed below.

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No. 47696-7-II

3. Automatic Renewal

Kimbra argues that RCW 59.12.030(1) is inapplicable because her lease term did not

expire on December 31, 2014, but instead automatically renewed as required in 42 U.S.C.

§ 1437d(l)(1). Focusing only on the text of 42 U.S.C. § 1437d(l)(1), the statutory language is

consistent with Kimbra’s claim that her lease renewed automatically even though it had been

terminated. 42 U.S.C. § 1437d(l)(1) states that PHAs must utilize public housing leases that

“shall be automatically renewed for all purposes except for noncompliance with the requirements

[relating to community service].” The automatic renewal subsection does not list an exception

for termination of the lease, as allowed under other subsections of 42 U.S.C. § 1437d(l).

However, when determining the plain language of a statute, we consider not only the text

of the provision at issue but also the context of the provision, related provisions, and the statutory

scheme as a whole. Gray, 181 Wn.2d at 339. This principle means that we cannot interpret