state law acts as an obstacle to the accomplishment of the federal purpose.’”
Progressive Animal Welfare Soc’y v. Univ. of Wash., 125 Wn.2d 243, 265, 884
P.2d 592 (1994) (quoting Wash. State Physicians Ins. Exch. & Ass’n v. Fisons,
122 Wn.2d 299, 326, 858 P.2d 1054 (1993)).
Here, however, in enacting our state’s notice requirements for residential
evictions, our legislature wisely envisioned circumstances in which federal
statutes would provide tenants with additional protections. Thus, the RLTA itself
9
The Supremacy Clause provides:
This Constitution, and the laws of the United States which shall be made
in pursuance thereof; and all treaties made, or which shall be made, under the
authority of the United States, shall be the supreme law of the land; and the
judges in every state shall be bound thereby, any thing in the Constitution or laws
of any state to the contrary notwithstanding.
U.S. CONST. art. VI, cl. 2.
12
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 84119-0-I/13
contemplates that federal notice requirements may supplant the 14-day notice to
pay or vacate required by state law. See RCW 59.18.057(3) (providing that the
form for compliance with RCW 59.12.030(3)’s 14-day notice requirement “does
not abrogate any additional notice requirements to tenants as required by
federal, state, or local law”). Because our state law explicitly provides for
additional notice requirements imposed on landlords by federal mandate,
Sherwood Auburn is incorrect that a conflict is created by the imposition of a 30-
day notice requirement.
Indeed, we have previously held that, when a landlord accepts the
financial benefits of a federal program, the federal protections provided to tenants