source of legislative intent. State v. Chhom, 162 Wn.2d 451, 460 n.3, 173 P.3d 234
(2007). Federal courts have looked to section headings in federal legislation for “clues”
to congressional intent. Merit Mgmt. Grp., LP v. FTI Consulting, Inc., 583 U.S. 366,
380, 138 S. Ct. 883, 200 L. Ed. 2d 183 (2018) (recognizing that section headings cannot
limit the plain meaning of statute but “‘they supply cues’” as to what Congress intended
(citing Fla. Dep’t of Revenue v. Piccadilly Cafeterias, Inc., 554 U.S. 33, 47, 128 S. Ct.
2326, 171 L. Ed. 2d 203 (2008), and quoting Yates v. United States, 574 U.S. 528, 540,
135 S. Ct. 1074, 191 L. Ed. 2d 64 (2015))). Here, the section heading adopted in the
CARES Act emphasizes the limited time frame of the eviction moratorium and, by
implication, the basis of the paused evictions—nonpayment of rent. 15 U.S.C. § 9058(b),
(c)(2). Interpreting the 30-day notice requirement as applying to nonpayment of rent
connects § 9058(c)(2) to its section heading, whereas applying the notice to all evictions
disconnects the subsection from the heading.
9
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Hous. Auth. v. Knight, No. 102905-5
The context of the CARES Act also demonstrates that it was intended primarily to
provide economic support to tenants during an emergency situation, not to alter the
general eviction laws of every state. As Division One reasoned below, the short title of
the CARES Act is the “Coronavirus Aid, Relief, and Economic Security Act,” which is
further split into divisions relating to economics: “Keeping Workers Paid and Employed,
Health Care System Enhancements, and Economic Stabilization” and “Emergency