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No. 74434-8-1 >
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DIVISION ONE C.4D
CD
V.
NATE PRUDHON, PUBLISHED OPINION
Appellant. FILED: December 12, 2016
SPEARMAN, J. — In Seattle, a landlord may only evict a tenant if he or she
has "just cause" as provided in the Just Cause Eviction Ordinance (JCEO).
Seattle Municipal Code (SMC) § 22.206.160. Under the ordinance, "just cause"
exists if the landlord "elects to sell" a rental property as that term is defined in the
ordinance. Here, the landlord, relying on the "elects to sell" provision, gave the
tenant notice of just cause for eviction after she had already sold the home. The
issue is whether the landlord may properly invoke the "elects to sell" provision
when the rental property was already sold with the tenant in place. We conclude
the "elects to sell" just cause provision applies only to the prospective sale of a
rental property. Because there was no just cause for eviction in this case, the trial
court's order granting unlawful detainer was in error. We reverse.
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 74434-8-1/2
FACTS
Nate Prudhon leased a single-family home in Seattle from Denise and
Robert Burnside (Burnsides). After a one year lease expired at the end of June
2012, the tenancy reverted to month-to-month. Prudhon continued to reside at
the house. On or about April 2, 2015, the Burnsides entered into a purchase and
sale agreement with Blueprint Capital Services, LLC, who assigned the
agreement to R. Thoreson Homes, LLC. As part of the purchase and sale
agreement, the Burnsides agreed to issue a notice terminating Prudhon's