Appropriations for Coronavirus Health Response and Agency Operations.” Knight, 30
Wn. App. 2d at 104 (quoting 134 Stat. at 281, 285). Section 9058 is located in Title IV,
“Economic Stabilization and Assistance to Severely Distressed Sectors of the United
States Economy,” within “Subtitle A—Coronavirus Economic Stabilization Act of
2020.” Id. While the CARES Act contains topics other than economics, as does any
omnibus legislation, its short title, divisions, and other titles relate primarily to economic
stabilization, financial assistance, and monetary relief. Id. at 105-06. This context
supports Congress’s intent to provide relief to tenants during the pandemic via limiting
evictions for the economic reason of failure to pay rent.
A handful of courts from other jurisdictions have considered the issue and agree
with the plain language analysis, though they are largely unpublished and do not
comprehensively analyze the notice requirement’s statutory language. See id. at 109-111
(discussing W. Haven Hous. Auth. v. Armstrong, No. NHHCV206013057S, 2021 WL
2775095, at *3 (Conn. Super. Ct. Mar. 16, 2021) (unpublished) (Connecticut trial court
concluding § 9058’s plain language did not require providing 30 days’ notice to evict
10
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Hous. Auth. v. Knight, No. 102905-5
based on nuisance); Watson v. Vici Cmty. Dev. Corp., No. CIV-20-1011-F, 2022 WL
910155 (W.D. Okla. Mar. 28, 2022) (court order) (federal court in Oklahoma implicitly
concluded the 30-day notice applied only to vacate for nonpayment of rent); CP Com.
Props., LLC v. Sherman, 53,897 (La. App. 2 Cir. 4/14/21), 318 So.3d 445 (Louisiana
court holding the same)).