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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was passed, the 117th Congress commenced after an intervening general

election. This Congress passed the American Rescue Plan Act of 2021. Pub. L.

No. 117-2, § 2912, 135 Stat. 6, 51-52; § 3201, 135 Stat. at 54-58; § 3201(h), 135

Stat. at 58; § 3206, 135 Stat. at 63-67 (2021). In that bill, Congress amended a

portion of the Emergency Rental Assistance provision and set forth three

additional provisions, one underneath the subtitle of “Ratepayer Protection,” titled

“Funding for Water Assistance Program,” and the other two, underneath the

subtitle of “Housing Provisions,” titled “Emergency Rental Assistance,” and

“Homeowner Assistance Fund.” 135 Stat. at 51-52, 54-58, 63-67. The 117th

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No. 85031-8-I/22

Congress indicated that those provisions were to be codified at 15 U.S.C. §§

9058b, 9058c, 9058d. 135 Stat. at 51, 54, 63.

The enactment of the American Rescue Plan Act of 2021 by the 117th

Congress is a better source of legislative intent than the CRS report. A

significantly similar number of congressional members of the 117 Congress

voted on both the CARES Act and the American Rescue Plan Act of 2021.

Furthermore, the 117th Congress’s enactment similarly indicated that those

provision were to be located at 15 U.S.C. §§ 9058b, 9058c, and 9058d,

immediately adjacent to 15 U.S.C. § 9058. Those provisions, like the Emergency

Rental Assistance provision above, also focused on economic relief and

stabilization in utilities, rental housing (again), and homeownership. Therefore,

even though the 117th Congress’s enactment and placement of the listed

provisions are not necessarily a reliable indication of the 116th Congress’s intent,