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

Here, before her eviction Kimbra received notice of the grounds for terminating her lease

and had an opportunity to argue her case in a formal hearing before a neutral decision maker.

This procedure complied with the notice and hearing requirements of procedural due process.

Kimbra cites no authority for her claim that due process includes an opportunity for a public

housing tenant to cure a lease violation before being evicted. We hold that Housing Kitsap’s

termination of Kimbra’s lease and eviction did not violate due process.

b. Equal Protection

Kimbra also argues that her eviction under RCW 59.12.030(1) rather than RCW

59.12.030(4) violates equal protection guarantees in the Fourteenth Amendment and article I,

section 12 of the Washington Constitution. She claims that tenants who receive notices of

termination near the end of their leases are treated differently than tenants who receive notices of

termination in the middle of the leases. For the former group, a landlord can wait until the lease

expires and bring an unlawful detainer action without giving an opportunity to cure under RCW

59.12.030(1). For the latter group, the landlord must give an opportunity to cure before bringing

an unlawful detainer action under RCW 59.12.030(4).

16
             

No. 47696-7-II

But Kimbra does not explain why application of the two subsections violates equal

protection. And she cites no authority to support her equal protection argument. We will not

consider arguments for which a party has not cited legal authority. Johnson Forestry

Contracting, Inc. v. Dep’t of Nat. Res., 131 Wn. App. 13, 25, 126 P.3d 45 (2005). “ ‘[N]aked