Wash. Supreme Court published opinion — 901791.pdf

First, while RCW 59.20.040 provides that certain statutes do or do not apply

in determining "legal rights, remedies, and obligations arising from any rental

agreement between a landlord and a tenant regarding a mobile home lot," all the

specific statutes referenced relate to forcible entry and unlawful detainer actions.

None relate to the formation of leases. This makes perfect sense because the

rights, remedies, and obligations arising from a contract are not the same as

requirements for entering into a contract. The MHLTA also recognizes that both

landlords and tenants must comply with "other applicable statute[s], regulation[s],

or ordinance[s] of the state, county, or municipality" that are not found in the

MHLTA. RCW 59.20.070(5)(b); see also RCW 59.20.080(l)(i).

Second, while oral leases may be enforceable from month to month, Labor

Hall, 24 Wn.2d at 87-88, under the MHLTA the tenant is entitled to "a written

rental agreement, signed by the parties," for a lease of any duration, RCW

59.20.060(1). The plain language of this provision ensures a minimum of

formality for all MHLTA leases, even if the tenant chooses to enter a month-to-

month lease. See RCW 59.20.050(1). But the fact that RCW 59.20.060(1) creates

a minimum of formality for even the shortest MHLTA leases does not establish an

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Western Plaza, LLC v. Tison, No. 90179-1
Yu, J. (dissenting)

irreconcilable conflict with RCW 59.04.010's one-year limit on enforcing the

provisions of written, unacknowledged leases.

Third, the duration of a lease subject to the MHLT A is presumptively one

year. RCW 59.20.090(1). This provision does irreconcilably conflict with the