the tenant with a notice to vacate.” The plain language of this statute requires a landlord to
provide the tenant with a 30-day notice to vacate before requiring the tenant to vacate the
premises. Division One of this court agreed: “Indeed, the plain language of the CARES Act
mandates that a landlord that has received certain federal financial benefits must provide such a
6
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 58118-3-II
[30-day] notice to tenants residing in housing units covered by the Act.” Sherwood Auburn, LLC
v. Pinzon, 24 Wn. App. 2d 664, 669, 521 P.3d 212 (2022), review denied, 1 Wn.3d 1005 (2023).
Pendleton Place disputes this interpretation, making two arguments. First, Pendleton
Place claims that 15 U.S.C. § 9058(c)(1) is limited by the eviction moratorium provisions in
subsection (b), and applies only to eviction for nonpayment of rent. But this argument is
inconsistent with the language of 15 U.S.C. § 9058(c)(1). There is no language in 15 U.S.C.
§ 9058(c)(1) limiting its applicability to eviction related to nonpayment of rent. The eviction
moratorium in 15 U.S.C. § 9058(b) contains such a limitation. 15 U.S.C. § 9058(c)(1) does not.
The Congressional Research Service (CRS)2 issued a report addressing this question.
MAGGIE MCCARTY & DAVID H. CARPENTER, CONG. RSCH. SERV., “CARES ACT EVICTION
MORATORIUM,” (April 7, 2020),
https://crsreports.congress.gov/product/pdf/IN/IN11320#:~:text=Section%204024%20of%20the
%20CARES,assistance%20or%20federally%20related%20financing [https://perma.cc/YRK4-
4BE9]. The report states: