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)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
- Western Plaza, LLC v. Tison, 184 Wash. 2d 702 (2015)
Full Text
1,674 chars¶47 From the perspective of tenant protection, the statute of frauds’ requirement of an acknowledged signature is not an empty formality or a bureaucratic hoop to jump through. It requires an authorized, uninterested third party to certify that the person to be bound by a contract is (1) the person who actually signs it and (2) entering the contract “freely and voluntarily.” RCW 64.08.050; see also RCW 42.44.010(4) (defining “acknowledgement” as “a statement by a person that the person has executed an instrument as the person’s free and voluntary act”). A public official who is authorized to take acknowledged signatures has the duty to prevent forgery and to ensure that the person signing the contract is not acting under duress, coercion, mental incapacity, or some other incompetency. See, e.g., RCW 42.44-.080(2), .160; Werner v. Werner, 84 Wn.2d 360, 366-67 & n.1, 526 P.2d 370 (1974); Jackson v. Tatebo, 3 Wash. 456, 462-65, 28 R 916 (1892). A private landlord with a direct pecuniary interest does not necessarily have such an incentive—it is much easier to obtain a favorable agreement with an identity thief or a person without the capacity to understand the contract’s terms or implications. A particularly dishonest landlord might even add or modify terms to the lease after the tenant has signed it in an effort to enforce a different agreement from the one that the tenant thought she was entering into. See Lohnes v. Meenk Lumber Co., 18 Wn.2d 251, 252-54, 138 P.2d 885 (1943). With RCW 59.04-.010, the legislature determined that the risk of such un*725scrupulous behavior was acceptable for leases that did not . exceed one year, but not beyond that.