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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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¶19 These statutes can be harmonized only by applying each statute to the specific transactions they regulate. RCW *71364.04.010 applies to the transfer of title and requires that all conveyances of real estate be in writing and acknowledged, regardless of the duration of the conveyance. RCW 59.04.010 applies to tenancies generally and requires that leases over one year be in writing and acknowledged. RCW 59.20.060 applies specifically to mobile home lots and provides that leases over one year are valid if they are in writing; it does not require acknowledgement. It is otherwise impossible to reconcile the statutes: a MHLTA lease lasting over a year is either governed by RCW 59.04.010 and requires acknowledgement or it is governed by RCW 59.20.060 and it does not.