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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Kiemle & Hagood Company v. Mariam P. Daniels a/k/a Phoebe Daniels (2023)

Citation
Kiemle & Hagood Company v. Mariam P. Daniels a/k/a Phoebe Daniels (2023)
Parent Document
Kiemle & Hagood Company v. Mariam P. Daniels a/k/a Phoebe Daniels (2023)
Jurisdiction
Washington (state)
Effective Date
2023-04-27

Other Sections in This Document (519)

Full Text

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                The “specificity” requirement in RCW 59.18.650(6)(b), effective since May
       2021, has not yet been interpreted by an appellate court. Ms. Daniels points out that
       federal regulations governing evictions from federally subsidized projects impose a
       comparable requirement. See 24 C.F.R. § 247.4(a)(2) (“The landlord’s determination
       to terminate the tenancy shall . . . state the reasons for the landlord’s action with enough
       specificity so as to enable the tenant to prepare a defense . . . .” (emphasis added)).
       Given the scarcity of Washington authority on point, we may look to foreign cases
       interpreting such federal regulations, such as Pyrtle and Swords to Plowshares, for
       guidance. See In re Welfare of Colyer, 99 Wn.2d 114, 119, 660 P.2d 738 (1983).