Mathew Howard, V. James Pinkerton (2023)

Citation: Mathew Howard, V. James Pinkerton (2023)
Parent Document: Mathew Howard, V. James Pinkerton (2023)
Jurisdiction: Washington (state)
Effective Date: 2023-05-02
Original Source: https://www.courtlistener.com/opinion/9440169/mathew-howard-v-james-pinkerton/ ↗

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         Howard and Forland argue that references to “residence” or “principal residence” in the
       Manufactured/Mobile Home Landlord-Tenant Act (chapter 59.20 RCW), homestead exemption
       statutes for enforcement of judgments, and property tax exemption statutes should guide our
       interpretation of RCW 59.18.650(2)(d). However, as discussed in this opinion, the plain language
       of RCW 59.18.650(2)(d) makes clear that “principal residence” refers to a unit being used as a
       dwelling place or living quarters. Further, none of the statutes cited by Howard and Forland refer
       to the Residential Landlord-Tenant Act or indicate in any way that their use of “residence” or
       “principal residence” should guide the interpretation of RCW 59.18.650(2)(d). See RCW
       59.20.030(11); RCW 6.13.010, .050; RCW 84.36.383(12). Because RCW 59.18.650(2)(d) is
       unambiguous, the language in the statute controls, and we need not rely on other references in
       unrelated statutory provisions. See Jones v. Dep’t of Lab. & Indus., 17 Wn. App. 2d 437, 445, 486
       P.3d 949 (2021) (use of terms in statutes that are unrelated and address different subjects are not
       helpful for discerning plain meaning).

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