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Wash. Supreme Court published opinion — 1029055.pdf

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Wash. Supreme Court published opinion — 1029055.pdf
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Washington (state)
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Appropriations for Coronavirus Health Response and Agency Operations.” Knight, 30

Wn. App. 2d at 104 (quoting 134 Stat. at 281, 285). Section 9058 is located in Title IV,

“Economic Stabilization and Assistance to Severely Distressed Sectors of the United

States Economy,” within “Subtitle A—Coronavirus Economic Stabilization Act of

2020.” Id. While the CARES Act contains topics other than economics, as does any

omnibus legislation, its short title, divisions, and other titles relate primarily to economic

stabilization, financial assistance, and monetary relief. Id. at 105-06. This context

supports Congress’s intent to provide relief to tenants during the pandemic via limiting

evictions for the economic reason of failure to pay rent.

A handful of courts from other jurisdictions have considered the issue and agree

with the plain language analysis, though they are largely unpublished and do not

comprehensively analyze the notice requirement’s statutory language. See id. at 109-111

(discussing W. Haven Hous. Auth. v. Armstrong, No. NHHCV206013057S, 2021 WL

2775095, at *3 (Conn. Super. Ct. Mar. 16, 2021) (unpublished) (Connecticut trial court

concluding § 9058’s plain language did not require providing 30 days’ notice to evict

10
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Hous. Auth. v. Knight, No. 102905-5

based on nuisance); Watson v. Vici Cmty. Dev. Corp., No. CIV-20-1011-F, 2022 WL

910155 (W.D. Okla. Mar. 28, 2022) (court order) (federal court in Oklahoma implicitly

concluded the 30-day notice applied only to vacate for nonpayment of rent); CP Com.

Props., LLC v. Sherman, 53,897 (La. App. 2 Cir. 4/14/21), 318 So.3d 445 (Louisiana

court holding the same)).