§ 9058

Citation: § 9058
Parent Document: Hous. Auth. v. Knight, 563 P.3d 1058 (2025)
Jurisdiction: Washington (state)
Effective Date: 2025-02-20
Original Source: https://www.courtlistener.com/opinion/10336415/hous-auth-v-knight/ ↗

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  The parties also disagree whether the clear statement rule is confined to construing ambiguous
provisions. In Spector, the Supreme Court applied the clear statement rule to an unambiguous
statute, and in Hayden, 449 F.3d at 325, the Second Circuit Court of Appeals held the rule “does
not require courts engaged in statutory interpretation to search for a construction of the statute
that will not affect the federal balance, but rather, reveals the canon to be a default rule.”
(Emphasis added.) Based on Spector and Hayden, we assume without deciding that the clear
statement federalism rule operates as a tool to discern congressional intent and may be applied to
an unambiguous statute.
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Hous. Auth. v. Knight, No. 102905-5

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