“are properly considered as limitations to our state’s unlawful detainer statute.” Indigo Real
Estate Servs. v. Wadsworth, 169 Wn. App. 412, 423, 280 P.3d 506 (2012).
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No. 58118-3-II
A trial court cannot grant relief in an unlawful detainer action if the landlord has not
provided the required notice to vacate or cure. Kitsap County Consol. Hous. Auth. v. Henry-
Levingston, 196 Wn. App. 688, 699, 385 P.3d 188 (2016). “Such noncompliance prevents the
trial court from exercising its jurisdiction.” Id.
2. Statutory Interpretation
We view questions of statutory interpretation de novo. Ekelmann v. City of Poulsbo, 22
Wn. App. 2d 798, 807, 513 P.3d 840 (2022). When interpreting a federal statute, our objective is
to ascertain the intent of Congress. Henry-Levingston, 196 Wn. App. at 701. “We consider the
language of the statute, the context of the statute, related statutes, and the statutory scheme as a
whole.” Ekelmann, 22 Wn. App. 2d at 807.
If the plain statutory language is unambiguous, we apply that language as written.
Dzaman v. Gowman, 18 Wn. App. 2d 469, 479, 491 P.3d 1012 (2021). We cannot use statutory
interpretation to add language that the legislature did not use. Miller v. Dep’t of Revenue, 27
Wn. App. 2d 415, 423, 532 P.3d 187 (2023). And this court does not “rewrite plain statutory
language under the guise of construction.” McColl v. Anderson, 6 Wn. App. 2d 88, 91, 429 P.3d
1113 (2018).
3. Plain Language of 15 U.S.C. § 9058(c)(1)
15 U.S.C. § 9058(c)(1) states that a lessor “may not require the tenant to vacate the
covered dwelling unit before the date that is 30 days after the date on which the lessor provides