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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interpretation provided herein would constitute an improper addition of language to Section 4024
that Congress did not intend. We disagree. By connecting the provisions of Section 4024 to one
another, it was plainly Congress’s intent to set forth the nonpayment of rent basis in subsection
(b) also in subsection (c) by implication. Acknowledging implication is not addition.

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For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
No. 85031-8-I/10

of a provision set forth within that context. Linville, 11 Wn. App. 2d at 321

(quoting One 1970 Chevrolet Chevelle, 166 Wn.2d at 839).

The short title of the CARES Act bill was the “Coronavirus Aid, Relief, and

Economic Security Act.” § 1, 134 Stat. 281 (emphasis added) (capitalization

omitted). The Act was broken down into two divisions, Division A, “Keeping

Workers Paid And Employed, Health Care System Enhancements, and

Economic Stabilization,” and Division B, “Emergency Appropriations for

Coronavirus Health Response and Agency Operations.” 134 Stat. at 285

(emphasis added) (capitalization omitted). Division A set forth six titles, “Title I—

Keeping American Workers Paid and Employed Act,” “Title II—Assistance for

American Workers, Families, and Businesses,” “Title III—Supporting America’s

Health Care System in the Fight Against the Coronavirus,” “Title IV—Economic

Stabilization and Assistance to Severely Distressed Sectors of the United States

Economy,” “Title V—Coronavirus Relief Funds,” and “Title VI—Miscellaneous

Provisions.” 134 Stat. at 281-85 (emphasis added) (capitalization omitted).

Congress located the pertinent notice provision of Section 4024 in Division

A, Title IV, Subtitle A—“Coronavirus Economic Stabilization Act of 2020,”

adjacent to 28 other sections.