Indigo Real Estate Services, Inc. v. Wadsworth, 169 Wash. App. 412 (2012)

Citation: Indigo Real Estate Services, Inc. v. Wadsworth, 169 Wash. App. 412 (2012)
Parent Document: Indigo Real Estate Services, Inc. v. Wadsworth, 169 Wash. App. 412 (2012)
Jurisdiction: Washington (state)
Effective Date: 2012-07-09
Original Source: https://www.courtlistener.com/opinion/4951771/indigo-real-estate-services-inc... ↗

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¶25 Courts in other jurisdictions have likewise concluded that landlords must comply with the provisions of the statutes and regulations governing section 8 tenancies. See Sudersan v. Royal, 386 N. J. Super. 246, 253-54, 900 A.2d 320 (2005); 1212 Grand Concourse LLC v. Ynguil, 27 Misc. 3d 205, 211, 894 N.Y.S.2d 713 (N.Y. Civ. Ct. 2010). As the New York Court of Appeals has explained, “[s]ection 1437f restricts the ability of landlords receiving Section 8 subsidies to evict tenants ... ‘during the term of the lease ... except for serious or repeated violation of the terms and conditions of *423the lease, for violation of applicable Federal, State, or local law, or for other good cause.’ ” Rosario v. Diagonal Realty, LLC, 8 N.Y.3d 755, 762, 872 N.E.2d 860, 840 N.Y.S.2d 748 (2007) (quoting 42 U.S.C. § 1437f(d)(l)(B)(ii)). The Ninth Circuit has likewise determined that, “[b]y enacting the federal good cause requirement, [Congress] desired to maintain a uniform federal floor below which protections for tenants could not drop.” Barrientos v. 1801-1825 Morton LLC, 583 F.3d 1197, 1211 (9th Cir. 2009).

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