accomplish the purpose for which it is enacted.” State v. Douty, 92 Wn.2d 930, 936,
603 P.2d 373 (1979); cf. Randy Reynolds & Assocs. v. Harmon, 193 Wn.2d 143,
156, 437 P.3d 677 (2019) (Chapter 59.18 RCW is a “statute[] in derogation of the
common law and thus [is] strictly construed in favor of the tenant.”). The RLTA
creates remedies for tenants in order “to protect several tenant interests susceptible
to the landlord’s ‘upper hand,’ which is especially strong in times of housing
shortages.” Bothwell, supra, at 559. 14 Further, the RLTA provides for costs and fees
for violations of its deposit provisions and double damages for willful violations of
the deposit return provision at issue here. RCW 59.18.280(2); see Schilling v. Radio
Holdings, Inc., 136 Wn.2d 152, 157-59, 961 P.2d 371 (1998) (concluding that the
wage rebate statute “must be liberally construed to advance the Legislature’s intent
to protect employee wages and assure payment,” in part, because the legislature
provided for exemplary damages and costs and attorney fees).
14
But see Bothwell, supra, at 561-63 (noting several aspects of the RLTA that diminish its
remedial effect); Richard E. Blumberg, Analysis of Recently Enacted Arizona and Washington
State Landlord-Tenant Bills, 7 CLEARINGHOUSE REV. 134, 134 (1973) (observing that the URLTA
and many state laws that resemble it “have done little or nothing to alleviate the hardships of low
and moderate income tenants caused by the inadequate supply of affordable, habitable housing
and the commensurate lack of bargaining power of such tenants”).
15
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Silver v. Rudeen Mgmt. Co.
No. 98024-1
Silver’s action seeks to recover his deposit. A security deposit is the tenant’s