Wash. Court of Appeals published opinion — 850318.pdf

Citation: Wash. Court of Appeals published opinion — 850318.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/850318.pdf ↗

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It follows that Congress, by implication, intended that the nonpayment of

rent basis provided in subsection (b) apply to both paragraph (c)(1) and

8
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No. 85031-8-I/9

paragraph (c)(2).9 Indeed, by extending the protections set forth in subsection

(b) only to evictions stemming from nonpayment of rent, and by clearly intending

that subsection (b) and (c) be read as one, Congress demonstrated its intent to

extend the protections in subsection (c) only to evictions stemming from

nonpayment of rent. Thus, the plain meaning of Section 4024’s 30-day notice to

vacate provision is that it applies only to evictions stemming from nonpayment of

rent.

2

The statutory context underlying the CARES Act also guides our

interpretation of the notice to vacate provision here at issue.

As set forth above, a statute’s plain meaning is derived from inquiring into

“all that the Legislature has said in the statute and related statutes which disclose

legislative intent about the provision in question.” Dep’t of Ecology, 146 Wn.2d at

11. “The title of a legislative act also may be referred to as a source of legislative

intent.” Covell v. City of Seattle, 127 Wn.2d 874, 887-88, 905 P.2d 324 (1995)

(citing Wash. Optometric Ass’n v. County of Pierce, 73 Wn.2d 445, 449, 438 P.2d

861 (1968); In re Kurtzman’s Estate, 65 Wn.2d 260, 265, 396 P.2d 786 (1964)),

modified on other grounds by Yim v. City of Seattle, 194 Wn.2d 682, 702, 451

P.3d 694 (2019). In that sense, the statutory context can guide our interpretation

9 Amicus King County Bar Association Housing Justice Project suggests that the