4
Indeed, the next sentence in RCW 59.18.365(1) states that the summons must also contain an
address for service of the “notice of appearance or answer.” (Emphasis added.) Subsection (2)
provides that a defendant may serve a copy of “an answer or notice of appearance.” RCW
59.18.365 (emphasis added). RCW 59.18.365(1) is not consistent with its requirements for
defendants, directing them to appear and answer as well as appear or answer.
15
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Sangha v. Keen et al., No. 103332-0
and an answer. Subsection (3) instructs the opposite. It states expressly that the
defendant “may respond with a ‘notice of appearance,’” and the rest of the subsection
concerns where to respond and the consequences of a response. The landlord here used
the statutory summons form verbatim. Compare RCW 59.18.365(3), with CP at 11-13
(summons). “‘A specific statute will supersede a general one when both apply.’”
Kustura v. Dep’t of Lab. & Indus., 169 Wn.2d 81, 88, 233 P.3d 853 (2010) (quoting
Waste Mgmt. of Seattle, Inc. v. Util. & Transp. Comm’n, 123 Wn.2d 621, 630, 869 P.2d
1034 (1994)). We construe unlawful detainer statutes strictly in favor of the tenant.
Terry, 114 Wn.2d at 563. Accordingly, as discussed above, we hold that the more
specific directions in subsection (3) instruct defendants only to respond by written
appearance.
The landlord also asserts that RCW 59.18.640 and SPR 98.24W do not “attach to
general civil proceedings, such as CR 55 default judgment hearings.” Br. of Resp’t at 3-
4, 46-47. In the landlord’s view, neither authority references court rules or general
proceedings, and both depend on the prerequisites of available funding and a factual basis