Little Mountain Estates Tenants Association v. Little Mountain Estates MHC LLC

Summary

The Washington Supreme Court held that the Manufactured/Mobile Home Landlord-Tenant Act permits a landlord and tenant to agree to a 25-year rental term that becomes a one- or two-year term if the tenant assigns the agreement. The court concluded that this provision did not waive the tenant's statutory right to assign the rental agreement and did not violate the MHLTA, while remanding the separate Consumer Protection Act claim for further factual findings. Justice Alexander and three other justices dissented.

Holdings

1. The MHLTA permits a landlord and tenant to negotiate and agree to the term of a rental agreement, including a term determined by a formula or linked to the tenant's decision to assign the lease. The agreed provision providing a 25-year term for the original tenant and a one- or two-year term upon assignment therefore does not violate the MHLTA.
2. Because RCW 59.20.090(1) is unambiguous, statements of legislative intent are irrelevant to the statutory interpretation analysis and do not justify invalidating the assignment provision.

Questions Presented

1. Whether the MHLTA permits a landlord and tenant to agree to a 25-year rental term that becomes a one- or two-year term if the tenant assigns the rental agreement.
2. Whether the assignment provision unlawfully waives or restricts the tenant's statutory right to assign the rental agreement under the MHLTA.
3. Whether legislative-intent provisions of the MHLTA required invalidation of the assignment provision despite the plain language of RCW 59.20.090(1).

Disposition

reversed_and_remanded