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Wash. Court of Appeals published opinion — 389189_pub.pdf

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Wash. Court of Appeals published opinion — 389189_pub.pdf
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Washington (state)
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(2004) (“[N]o landlord . . . may ever use nonjudicial, self-help methods to remove a

tenant.”).

A landlord’s service of a notice to terminate a tenancy is not a remedy. It is a

legal prerequisite to avail oneself of the superior court’s jurisdiction. See Hall v.

Feigenbaum, 178 Wn. App. 811, 819, 319 P.3d 61 (2014). Because K&H did not pursue

a remedy under the RLTA within 60 days of providing Ms. Daniels with a notice to cure

or vacate under RCW 59.18.650(2)(b), the November 3 notice expired. The only notice

still operative by the time K&H filed suit on January 10, 2022, was the one dated

December 27, 2021.

Sufficiency of the December 27 notice

The December 27 notice was issued pursuant to RCW 59.18.650(2)(c), 2 which

allows a landlord to terminate a tenancy with three days’ notice based on “waste,”

“nuisance,” “unlawful activity that affects the use and enjoyment of the premises,” or

2
The notice also cited RCW 59.18.650(2)(b), which authorizes a landlord to
terminate a tenancy based on a “substantial breach” of a material lease term. However,
subsection (2)(b) requires a tenant be given 10 days to cure their noncompliance. Because
the December 27 notice did not provide such a cure period, it cannot fairly be read as
invoking subsection (2)(b). See Christensen v. Ellsworth, 162 Wn.2d 365, 372, 173 P.3d
228 (2007) (noting the time and manner requirements of notice demand strict
compliance). Thus, subsection (2)(c) was K&H’s only viable cause for eviction.

15
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 38918-9-III
Kiemle & Hagood Co. v. Daniels

“other substantial or repeated and unreasonable interference with the use and enjoyment

of the premises by the landlord or neighbors of the tenant.”