rules and unlawful detainer statutes). Though the rule allows a motion for default based
on the failure to answer, the statute informs tenants that they must respond to a summons
and equates a response only to a notice of appearance—not an appearance and an
answer. 3
Reynolds did state that CR 55 permits default judgment for failure to answer an
eviction complaint. 193 Wn.2d at 157. Reynolds is distinguishable, however. The tenant
in that case did not appear in the unlawful detainer action. And, while Reynolds cited
RCW 59.18.365 in support of the default statement, at issue was the 2008 version of the
statute. Reynolds was decided prior to the 2019 amendments in which lawmakers
3
RCW 59.12.120 provides that “[i]f on the date appointed in the summons the defendant does
not appear or answer, the court shall render judgment in favor of the plaintiff as prayed for in the
complaint.” (Emphasis added.) Neither party cites .120. Chapter 59.12 RCW governs forcible
entry and forcible and unlawful detainer. Chapter 59.18 RCW governs the RLTA. Both
chapters concern unlawful detainer actions but chapter 59.12 RCW is broader than chapter 59.18
RCW. For example, chapter 59.12 RCW includes unlawful detainer actions commenced as a
result of a trustee’s sale and hold over tenants on agricultural land. RCW 59.12.032, .035.
Chapter 59.18 RCW deals specifically with residential tenancies. Therefore, the specific
statutory requirements established in chapter 59.18 RCW apply in this case. See Pleasant, 126
Wn. App. at 390.
14
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Sangha v. Keen et al., No. 103332-0
clarified that a written notice of appearance constitutes a response to an eviction
summons. See LAWS OF 2019, ch. 356, § 9.