the landlords' actual intention to do so, the court found that the tenants failed to raise
a genuine issue of material fact. Id. Although N'Jie suggests that the tenant may
dispute the landlord's actual intentions before being evicted, the present case again
involves a distinct issue. Accordingly, N'Jie does not guide us in resolving this case.
Given the limited guidance in case law on the issue presented in this case, our
focus must be on reading the language of the ordinance in a commonsense manner.
We carefully examine the text in light of the stated purpose of the JCEO, which is
to "protect from eviction those tenants who may be subjected to misuse of those just
causes." Seattle Ordinance 117942, at 3 (Dec. 14, 1995). Indeed, the text of the
ordinance itself suggests that the city council intended to prevent "arbitrary
eviction[s]." SMC 22.200.020(D). In this regard, the JCEO should be understood
as remedial in nature. "'A remedial statute is one which relates to practice,
procedures[,] and remedies."' Densley v. Dep't of Ret. Sys., 162 Wn.2d 210, 223-
24, 173 P.3d 885 (2007) (quoting State v. McClendon, 131 Wn.2d 853, 861, 935
P.2d 1334 (1997) (plurality opinion)). "[W]e construe remedial statutes liberally in
accordance with the legislative purpose behind them." Jametsky v. Olsen, 179
-14-
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Faciszewski, et al. v. Brown, et al., 92978-5
Wn.2d 756, 763, 317 P.3d 1003 (2014). "The same rules of construction apply to
interpretations of municipal ordinances as to interpretations of state statutes." City
of Puyallup v. Pac. Nw. Bell Tel. Co., 98 Wn.2d 443, 448, 656 P.2d 1035 (1982).
Because the JCEO is a remedial ordinance designed to prevent arbitrary evictions,