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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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We reject Western Plaza’s attempts to harmonize the statutes. Western Plaza asserts that the writing expressly required in all leases by RCW 59.20.060(1) does not establish an irreconcilable conflict with RCW 64.04.010’s requirement for greater formality in longer term leases. However,- RCW 64.04.010 requires the same formality for every conveyance regardless of length; these formalities include writing and acknowledgement. RCW 64.04.010, .020. Additionally, even RCW 59.04.010 explicitly requires a writing for every lease; leases governed by that statute that last for over one year also require acknowledgement. The ■requirement of a writing always exists; Western Plaza’s reading would render RCW 59.20.060(1) superfluous.