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

castings into the constitutional sea are not sufficient to command judicial consideration and

discussion.’ ” Crystal Ridge Homeowners’ Ass’n v. City of Bothel, 182 Wn.2d 665, 679, 343

P.3d 746 (2015) (alteration in original) (internal quotation marks omitted) (quoting In re Rosier,

105 Wn.2d 606, 616, 717 P.2d 1353 (1986)). We reject Kimbra’s equal protection argument.

3. Premature Filing of Unlawful Detainer Action

Kimbra argues that even if her lease did not automatically renew after it was terminated

and RCW 59.12.030(1) applies, Housing Kitsap’s January 9, 2015 unlawful detainer action was

premature. As noted above, 42 U.S.C. § 1437d(l)(1) requires that PHA leases have a term of 12

months. Kimbra claims that because her lease did not start until January 10, 2014, her lease

expired on January 9, 2015 rather than on December 31, 2014 and therefore Housing Kitsap

could not bring an unlawful detainer action until January 10.

But Kimbra did not argue in the trial court that the unlawful detainer action was

premature. We generally do not consider issues raised for the first time on appeal. RAP 2.5(a);

Rash v. Providence Health & Servs., 183 Wn. App. 612, 625, 334 P.3d 1154 (2014), review

denied, 182 Wn.2d 1028 (2015). This rule encourages full development of issues before the trial

court and helps preserve judicial economy. Id.

Here, Kimbra not only failed to argue in the trial court that her lease expired on January

9, 2015, she affirmatively agreed that her lease term expired on December 31, 2014. In her

17
             

No. 47696-7-II

answer to Housing Kitsap’s unlawful detainer action she acknowledged that the initial term of