IN CLERK’S OFFICE
SUPREME COURT, STATE OF WASHINGTON SARAH R. PENDLETON
FEBRUARY 20, 2025 SUPREME COURT CLERK
IN THE SUPREME COURT OF THE STATE OF WASHINGTON
THE HOUSING AUTHORITY OF )
THE COUNTY OF KING, ) No. 102905-5
)
Respondent, ) En Banc
)
v. ) Filed: February 20, 2025
)
ANDRE KNIGHT, )
)
Petitioner. )
__________________________________)
MADSEN, J.—At issue in this case is whether the Coronavirus Aid, Relief, and
Economic Security Act (CARES Act) requires landlords to provide 30 days’ notice when
evicting tenants for any reason or only for nonpayment of rent. Pub. L. No. 116-136, 134
Stat. 281 (2020) (codified at 15 U.S.C. §§ 9001-9141). We hold that § 9058(c) of the
CARES Act requires 30 days’ notice when evicting a tenant only for failure to pay rent.
Accordingly, we affirm the Court of Appeals.
BACKGROUND
Angela Knight and her two children occupied a rental unit owned and managed by
the King County Housing Authority (Housing Authority). In January 2023, the Housing
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Hous. Auth. v. Knight, No. 102905-5
Authority served a notice to vacate the unit in three days based on alleged nuisance and
criminal conduct. The notice stated that this was not the first instance of nuisance and
criminal conduct at the Knights’ unit. The Housing Authority served multiple notices on
the Knights from 2013-2018, including transferal to another unit for a “fresh start,” but
the nuisance and criminal activity continued. Clerk’s Papers at 5.
The January 2023 notice listed specific grounds for the eviction. Knight received
multiple 10-day notices to comply or vacate due to unauthorized guests residing in and