Pham v. Corbett, 187 Wash. App. 816 (2015)

Citation: Pham v. Corbett, 187 Wash. App. 816 (2015)
Parent Document: Pham v. Corbett, 187 Wash. App. 816 (2015)
Jurisdiction: Washington (state)
Effective Date: 2015-05-26
Original Source: https://www.courtlistener.com/opinion/4956711/pham-v-corbett/ ↗

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*828¶19 The Tenants also argue that excluding relocation assistance claims from unlawful detainer proceedings would undermine the goals of the statute. We find this argument persuasive. The legislature’s stated purpose when it enacted RCW 59.18.085 was to prevent tenants from being forced to “remain [ ] in rental housing that does not meet the state’s minimum standards for health and safety because they cannot afford to pay the costs of relocation in advance of occupying new, safe, and habitable housing.” Laws of 2005, ch. 364, § 1. Requiring displaced tenants to bring separate actions for relocation assistance on the regular civil calendar would impose unnecessary delay and costs on top of the financial burdens involved in the moving process. In accordance with the statute’s purpose, we hold that an unlawful detainer action is an appropriate forum for relocation assistance claims under RCW 59.18.085. Implied Warranty of Habitability

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