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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)

Citation
Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
Parent Document
Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
Jurisdiction
Washington (state)
Effective Date
2015-11-25

Other Sections in This Document (78)

Full Text

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¶14 RCW 59.04.010 requires a lease to be in writing; leases over one year are legal if they are in writing and acknowledged. As discussed below, the MHLTA presumes that a lease is for one year and that any lease automatically renews. See RCW 59.20.090(1). Under Washington law, any automatic lease renewal must be added to the term of the *711lease for determining compliance with the statute of frauds. Danielsen, 24 Wn.2d at 85. Thus, if RCW 59.04.010 applied to MHLTA leases, the presumption would be that every manufactured home lot lease would need to be acknowledged. Tison’s lease satisfies the requirements of only the MHLTA statute of frauds. B. Structure, Language, and Purposes of the MHLTA 1. Plain language of the statute