120-day period. See Wash. Sup. Ct. oral arg., Housing Auth. v. Knight, No. 102905-5
(Nov. 21, 2024), at 10 min., 39 sec., video recording by TVW, Washington State’s Public
Affairs Network, https://tvw.org/video/washington-state-supreme-court-
2024111173/?eventID=2024111173. In Knight’s view, a tenant could not be evicted
during subsection (b)’s moratorium for nonpayment of rent but, without subsection
(c)(1), could be evicted for a “pretextual” reason, allowing the landlord to evade the
moratorium. Id. at 8 min., 18 sec. Thus, subsections (b) and (c)(1) prevented the
commencement of all evictions for 120 days, and, after that period ended, all evictions
require 30 days’ notice. See id. at 11 min., 53 sec.
Knight’s reading, however, renders subsection (b) either incomplete or
meaningless. First, during the moratorium, landlords would have to consult more than
the subsection specifically titled “Moratorium.” To understand what they could not do,
landlords would have had to consult the “Notice” subsection as well to learn that though
subsection (b) precluded evictions only for nonpayment of rent, subsection (c)(1)
expanded the types of evictions to include all evictions. But if (c)(1) indeed applies to all
evictions, it necessarily includes evictions for failure to pay rent. Congress would have
no reason to specify that subsection (b)’s 120-day moratorium was restricted to evictions
12
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Hous. Auth. v. Knight, No. 102905-5
for nonpayment of rent. Knight’s interpretation makes the statutory language on
nonpayment meaningless, and we must interpret statutes such that no provision is
rendered meaningless or superfluous. Whatcom County v. City of Bellingham, 128