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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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¶42 The legislative history unquestionably supports a holding that MHLTA leases are not exempt from the general tenancy statute of frauds. When we interpret statutes, “the legislature is presumed to be aware of its past legislation and judicial interpretations thereof.” In re Marriage of Little, 96 Wn.2d 183, 189-90, 634 P.2d 498 (1981). But in this case, we need not merely presume that the legislature was aware of the existing statute of frauds when it drafted the MHLTA—the relevant legislative history proves it was.