While the Housing Authority’s appeal was pending, Division Two of the Court of
Appeals held that the CARES Act’s notice requirement applies to all evictions in
Pendleton Place, LLC v. Asentista, 29 Wn. App. 2d 516, 526, 541 P.3d 397 (2024). In
Knight’s case a month later, Division One disagreed and held that the 30-day requirement
is limited to evictions for failure to pay rent. Hous. Auth. v. Knight, 30 Wn. App. 2d 95,
117, 543 P.3d 891 (2024).
Andre Knight learned of the case, retained the King County Housing Justice
Project to represent him, and sought discretionary review here. We granted review
primarily to resolve the conflict between Divisions One and Two of the Court of
Appeals. 1 Hous. Auth. v. Knight, 3 Wn.3d 1007 (2024). We have received amicus curiae
1
At oral argument, both parties urged the court to decide this case under the public interest
exception to mootness given the split in the Court of Appeals, and argued that the notice
requirement remains in effect. Wash. Sup. Ct. oral arg., Hous. Auth. v. Knight, No. 102905-5
(Nov. 21, 2024), at 1 min., 44 sec.; 2 min., 09 sec.; 18 min., 41 sec., video recording by TVW,
Washington State’s Public Affairs Network, https://tvw.org/video/washington-state-supreme-
court-2024111173/?eventID=2024111173. We agree.
3
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Hous. Auth. v. Knight, No. 102905-5
briefs from the Rental Housing Association of Washington and the Legal Aid of
Southeast and Central Ohio.
ANALYSIS
A. Evictions in Washington
The issue presented, whether § 9058’s notice provision applies to all evictions, is
one of first impression. Because Knight was evicted under Washington State statutory