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Wash. Court of Appeals published opinion — 324427.pub.pdf

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Wash. Court of Appeals published opinion — 324427.pub.pdf
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Washington (state)
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recording was later considered by the jury, and the jury found Mr. Kipp guilty of the

charged offenses. Id. On appeal, the Kipp court applied a de novo review to the order

denying suppression, and reversed the trial court's order. Id. at 726-29, 733. In

determining that de novo review was appropriate, the Kipp court emphasized that the trial

court "made no credibility or other determinations for which its firsthand observation of

the proceedings better positioned it to make," and that the evidence before the trial court,

i.e., the stipulation to background facts and the 10-minute recording, did not present

issues of fact. Id. at 728.

Here, the trial court reviewed documentary evidence that established the relevant

timelines for what happened and when. The trial court was not called on to resolve issues

of fact concerning what happened and when. Rather, it was called on to determine, given

what happened and when, whether the landlord's failure to timely provide the statutory

notice was "beyond the landlord's control." Because there was no conflicting evidence

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No. 32442-7-III
Goodeill v. Madison Real Estate

which the trial court reconciled to make this determination, our review of the trial court's

decision on this issue is de novo.

b. An improperly designated finding offact is treated as a conclusion oflaw

"If a determination concerns whether the evidence showed that something

occurred or existed, it is properly labeled a finding of fact, but if a determination is made

by a process of legal reasoning from, or interpretation of the legal significance of, the

evidentiary facts, it is a conclusion oflaw." Moulden & Sons, Inc. v. Osaka Landscaping