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Wash. Supreme Court published opinion — 1029055.pdf

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Wash. Supreme Court published opinion — 1029055.pdf
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Washington (state)
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120-day period. See Wash. Sup. Ct. oral arg., Housing Auth. v. Knight, No. 102905-5

(Nov. 21, 2024), at 10 min., 39 sec., video recording by TVW, Washington State’s Public

Affairs Network, https://tvw.org/video/washington-state-supreme-court-

2024111173/?eventID=2024111173. In Knight’s view, a tenant could not be evicted

during subsection (b)’s moratorium for nonpayment of rent but, without subsection

(c)(1), could be evicted for a “pretextual” reason, allowing the landlord to evade the

moratorium. Id. at 8 min., 18 sec. Thus, subsections (b) and (c)(1) prevented the

commencement of all evictions for 120 days, and, after that period ended, all evictions

require 30 days’ notice. See id. at 11 min., 53 sec.

Knight’s reading, however, renders subsection (b) either incomplete or

meaningless. First, during the moratorium, landlords would have to consult more than

the subsection specifically titled “Moratorium.” To understand what they could not do,

landlords would have had to consult the “Notice” subsection as well to learn that though

subsection (b) precluded evictions only for nonpayment of rent, subsection (c)(1)

expanded the types of evictions to include all evictions. But if (c)(1) indeed applies to all

evictions, it necessarily includes evictions for failure to pay rent. Congress would have

no reason to specify that subsection (b)’s 120-day moratorium was restricted to evictions

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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Hous. Auth. v. Knight, No. 102905-5

for nonpayment of rent. Knight’s interpretation makes the statutory language on

nonpayment meaningless, and we must interpret statutes such that no provision is

rendered meaningless or superfluous. Whatcom County v. City of Bellingham, 128