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

Citation: Wash. Court of Appeals published opinion — 389189_pub.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/389189_pub.pdf ↗

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to “identify . . . facts and circumstances,” rather than legal causes of action, with

“specificity”) (emphasis added). Here, it was abundantly clear K&H sought to evict

Ms. Daniels because she failed to keep her apartment clean and sanitary, as documented

by the various inspections of her property and repeated notices to cure. K&H’s notice

sufficiently apprised Ms. Daniels of the facts that K&H alleged rose to the level of waste,

nuisance, or interference with enjoyment of the property. We do not fault K&H for

including all four components of RCW 59.18.650(2)(c) in its notice. 4

Ms. Daniels also argues the notice to quit was insufficiently specific as to whose

rights were allegedly being interfered with by her conduct. An eviction can be justified

under RCW 59.18.650(2)(c) based on “substantial or repeated and unreasonable

interference with the use and enjoyment of the premises by the landlord or neighbors

of the tenant.” But, as noted by Ms. Daniels, K&H’s notice did not specify whether

4
Nor are we persuaded by Ms. Daniels’s argument that the notice’s use of slashes
and the phrase “and/or” rendered it impermissibly vague. Cf. Batchelor v. Madison Park
Corp., 25 Wn.2d 907, 924-25, 172 P.2d 268 (1946).

18
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

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

the victim of Ms. Daniels’s conduct was the landlord or a neighbor and, if a neighbor,

which one.

We disagree that identification of a specific victim was necessary to provide

Ms. Daniels sufficient notice under RCW 59.18.650(2)(c). To be sure, in some cases,

identifying victims is logically necessary to afford a tenant a meaningful ability to rebut