Wash. Supreme Court published opinion — 929785.pdf

Citation: Wash. Supreme Court published opinion — 929785.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/929785.pdf ↗

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and the Court of Appeals' resolution of other issues. We granted review solely on

the question of whether Tenants ''were entitled to a trial on the just cause for the

termination of the lease." Order, Faciszewski v. Brown, No. 92978-5 (Wash. Aug. 3,

2016).

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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Faciszewski, et al. v. Brown, et al., 92978-5

ANALYSIS

In revising the commissioner's ruling,2 the superior court interpreted the

JCEO as requiring a finding of just cause (and thus not permitting a trial) once the

landlord files a sworn certification of intent. VTP (Sept. 2, 2014) at 22-23. The

superior court's interpretation of a statute involves a question of law, which we

review de novo. King County v. Cent. Puget Sound Growth Mgmt. Hr'gs Bd., 142

Wn.2d 543, 555, 14 P.3d 133 (2000).

I. Background on Washington's Landlord-Tenant Law and Seattle's
JCEO

Title 59 RCW sets out Washington's landlord-tenant law. Chapter 59.12

RCW governs unlawful detainer actions, while chapter 59.18 RCW, known as the

Residential Landlord-Tenant Act of 1973 (RLTA), governs the rights and remedies

of residential landlords and tenants.

"An unlawful detainer action is a statutorily created proceeding that provides

an expedited method of resolving the right to possession of property." Christensen

v. Ellsworth, 162 Wn.2d 365, 370-71, 173 P.3d 228 (2007). The term "unlawful