The Allens make numerous arguments, but they primarily contend that the superior court erred
because the settlement agreement was void and unenforceable under this statute. Both the Allens
and Princeton request attorney fees.
We hold that the settlement agreement was void and unenforceable under RCW
59.18.230(1)(b) because it waived the Allens’ tenant rights. Accordingly, we reverse.
FACTS
I. BACKGROUND
In October 2022, Princeton conducted an inspection of the Allens’ apartment. Based on
the condition of the apartment, Princeton issued a three-day notice to quit for waste, nuisance, or
unlawful use of the premises. Princeton’s notice alleged that upon inspection, the apartment was
in a condition that could be described as grossly unsanitary, placing the Allens in violation of their
lease.
The Allens did not vacate the unit. About one month later, Princeton filed a complaint for
unlawful detainer. The complaint alleged that the premises were
excessively cluttered with garbage, debris, and miscellaneous personal items,
blocking proper ingress and egress. The collection of food waste, debris, and
human waste was found to encourage pest infestation and create an extreme health
hazard to the property and surrounding residents.
2
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No. 58183-3-II
Clerk’s Papers (CP) at 2. Princeton requested a termination of the lease and restoration of
possession.
A show cause hearing was set, and the Allens filed a motion to dismiss. However, prior to
any hearings, Princeton and the Allens entered into a settlement agreement under CR 2A. Both
sides were represented by counsel.
II. SETTLEMENT AGREEMENT
The CR 2A settlement agreement imposed a number of obligations on the Allens. Broadly