In contrast to the eviction and late fee protections of Section [9058(b)], which are
expressly limited to nonpayment, Section [9058(c)] does not expressly tie the
notice to vacate requirement to a particular cause. Thus, Section [9058(c)]
arguably prohibits landlords from being able to force a tenant to vacate a covered
dwelling for nonpayment or any other reason until after August 24, 2020 (i.e.,
120 days after enactment, plus 30 days after notice is provided).
Id. at 1. Although CRS reports are not binding on this court, they can provide valuable insight
into the legislative intent behind federal laws. See Hawaii v. Trump, 878 F.3d 662, 688 n.15 (9th
2
The CRS serves Congress by providing research and analysis to support its legislative duties.
History and Mission of the Congressional Research Service, LIBR. OF CONG. (Sept. 16, 2021)
https://www.loc.gov/crsinfo/about/history.html [https://perma.cc/KVQ3-GWSW].
7
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 58118-3-II
Cir. 2017), rev’d on other grounds, 138 S. Ct. 2392, 201 L. Ed. 2d 775 (2018) (relying on CRS
report to interpret statute).
Pendleton Place’s argument would require us to add the limiting language in 15 U.S.C.
§ 9058(b) to 15 U.S.C. § 9058(c)(1). We decline to add language that Congress did not include.
See Miller, 27 Wn. App. 2d at 423. Instead, we conclude that the 30-day notice provision in 15
U.S.C. § 9058(c)(1) applies to all evictions of tenants living in covered dwelling units, not just
those for nonpayment of rent.
Second, Pendleton Place argues that it complied with 15 U.S.C. § 9058(c)(1) because it
did not commence eviction proceedings against Asentista until 30 days after serving the four 10-