Background
Ruby Caine leased a Seattle apartment from Riviera Northgate Apartments, LLC, in March 2024. After Caine failed to pay rent in July 2024, Riviera posted a 30-day notice to pay rent or vacate to her unit.
Riviera filed an ejectment complaint in August 2024 and moved for summary judgment the following month. The trial court granted judgment, attorney fees and costs, and a writ directing the sheriff to remove Caine and restore possession to Riviera. Caine appealed, arguing that ejectment was not a lawful means of pursuing her residential eviction and that she was protected by Washington’s Residential Landlord-Tenant Act of 1973 and the Seattle Municipal Code.
The Court’s Holding
The Court of Appeals held that the RLTA controls the eviction of residential tenants and that Riviera therefore could not use the general ejectment statute to evict Caine. Although both the ejectment statute and the RLTA can address recovery of possession following nonpayment of rent, the RLTA is the more specific statute because it expressly governs residential landlord-tenant relationships.
The court also held that the procedures and tenant protections established by the RLTA and the Seattle Municipal Code applied to Caine. Those protections include requirements associated with unlawful-detainer proceedings and potential defenses supplied by Seattle law. The court reversed the summary judgment and remanded for proceedings consistent with its ruling.
Key Takeaways
- The RLTA, rather than Washington’s general ejectment statute, controls an eviction arising from a residential tenancy.
- A landlord may not avoid the procedures and tenant protections governing residential eviction by styling the case as an ejectment action.
- Seattle’s applicable residential-tenant protections must be observed along with the requirements of the RLTA.
Why It Matters
The decision clarifies that ejectment is not an alternative route for removing a residential tenant when the RLTA applies. Washington landlords seeking possession from residential tenants must use the governing statutory process and comply with the protections that accompany it.
The ruling also confirms that local protections under the Seattle Municipal Code remain relevant in residential eviction proceedings and cannot be bypassed through selection of a different cause of action.