Wash. Supreme Court published opinion — 901791.pdf

term. /d. at 4-5 (noting that short-term leases gave the park owner a near dictatorial

authority because tenants are faced with the option of either abiding by the terms of

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Western Plaza, LLC v. Tison, No. 90179-1

a new lease, including rent increases or other odious provisions, or relocating their

residence at significant cost).

The purpose of the real estate statute of frauds is to prevent fraud in contractual

undertakings. Firth v. Lu, 146 Wn.2d 608, 614, 49 P.3d 117 (2002) (citing Miller v.

McCamish, 78 Wn.2d 821, 828, 479 P.2d 919 (1971)). The MHLTA specifically

addresses concerns of fraud by requiring that all rental agreements under the MHLTA

must be based on a written rental agreement that is signed by the parties, regardless

of the duration of the rental. RCW 59.20.060(1 ). In most tenancies, acknowledgement

serves as an additional protection against fraud in agreements that would encumber

land for over a year. But unlike most leases, the presumption under the MHLTA is for

a longer-term lease; acknowledgement provides an additional burden but no

additional protections from fraud than a writing provides.

The legislature created these protections for renters of mobile home lots in the

MHLTA. "Unless otherwise agreed rental agreements shall be for a term of one year,"

and landlords may not "offer a mobile home lot for rent to anyone without offering a

written rental agreement for a term of one year or more." RCW 59.20.090(1 ), .050(1 ).

"Any rental agreement of whatever duration shall be automatically renewed for the

term of the original rental agreement, unless a different specified term is agreed upon."