Indus., 140 Wn.2d 35, 43, 992 P.2d 1002 (2000).
Subsection 9058(c) contains two paragraphs. Paragraph (1) precludes landlords
from requiring a tenant to vacate prior to providing 30 days’ notice. 15 U.S.C. §
9058(c)(1). Paragraph (2) provides that such notice cannot be issued until after the 120-
day moratorium expires as set out in subsection (b). 15 U.S.C. § 9058(c)(2). These two
paragraphs are connected with the word “and.” We presume lawmakers use the term
“and” conjunctively. State v. Hodgins, 190 Wn. App. 437, 443-44, 360 P.3d 850 (2015)
(citing State v. Tiffany, 44 Wash. 602, 603-04, 87 P. 932 (1906); State v. Irizarry, 111
Wn.2d 591, 602, 763 P.2d 432 (1988) (Callow, J., concurring in part, dissenting in part)).
Thus, the plain language of subsection (c)(1) connects its 30-day notice provision to
subsection (c)(2). In turn, the plain language of subsection (c)(2) ties the notice
requirement of subsection (c)(1) to the failure to pay rent provision in subsection (b)(1).
8
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Hous. Auth. v. Knight, No. 102905-5
Reading the provisions together, subsection (b)’s 120-day moratorium must expire
before landlords may issue an eviction under subsection (c)(1). The moratorium is
limited to evictions for nonpayment of rent. 15 U.S.C. § 9058(b). Thus, subsection
(c)(2)’s reference to subsection (b) indicates that Congress intended to limit the 30-day
notice requirement, namely to evictions for failure to pay rent.
Significantly, the notice provision is located in the section titled “Temporary
moratorium on eviction filings.” 15 U.S.C. § 9058. Unlike captions generated by our
state code reviser, section headings adopted as a part of a statute may be referred to as a