concerns this appeal, RCW 59.18.625 regulates provisions related to late fees and other
charges over interest rate provisions of RCW 19.52.010.
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No. 39271-6-III
Heston v. Christensen
Further, Mr. Christensen’s reliance on Rental Housing Ass’n is misplaced. In
Rental Housing Ass’n, we concluded that RCW 19.52.010 entitles a party to
“prejudgment interest on any liquidated claim to compensate them for loss of use on
money wrongfully withheld by another party.” 22 Wn. App. 2d at 444 (emphasis added).
Here, Mr. Christensen engaged in source of income discrimination by rejecting payment
through a rental assistance program on behalf of Ms. Heston. Ms. Heston did not
wrongfully withhold money from Mr. Christensen for purposes of RCW 19.52.010.
Rather, Mr. Christensen wrongfully rejected payment made on behalf of Ms. Heston.
COUNT 10 – SECURITY DEPOSIT
Mr. Christensen asserts the trial court erred in concluding his refusal to return Ms.
Heston’s security deposit constituted a violation of former RCW 59.18.280(1) (2016).
Mr. Christensen claims that, under former RCW 59.18.280(2) (2016), circumstances
beyond his control prevented him from timely mailing documents related to the retention
of Ms. Heston’s security deposit.
Under former RCW 59.18.280(1), a landlord was allowed 21 days from the
termination of the lease agreement to provide their tenant a full and specific statement
explaining the basis for retaining a deposit. Unless the landlord can show circumstances
outside their control, should they fail to provide a tenant with the required documentation
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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 39271-6-III
Heston v. Christensen