Washington Hospitality Association v. Wilson — Court Affirmed That COVID-19 Does Not Qualify as a “Natural Disaster” for Property Tax Relief

The Court’s Holding

The Washington Court of Appeals affirmed the trial court, holding that the COVID-19 pandemic does not qualify as a “natural disaster” under RCW 84.70.010(1). The statute requires property to have been destroyed in whole or part, or to be in a declared disaster area and reduced in value by more than 20 percent “as a result of a natural disaster.” Although WHA’s properties were located in a declared disaster area, they sustained no physical damage from the pandemic.

The court interpreted “natural disaster” by examining dictionary definitions, related statutory provisions in Title 84, and the 1981 legislative amendment responding to the Mount St. Helens eruption. All evidence converged on a consistent definition: a physically destructive event in nature originating from Earth’s atmosphere, surface, or interior. Dictionary definitions uniformly described natural disasters as sudden, destructive natural events such as hurricanes, floods, earthquakes, and tsunamis—none mentioned pandemics, viruses, or illnesses. Related statutes in Washington law similarly characterized natural disasters as weather-related and physically destructive phenomena.

The court rejected WHA’s argument that the statute was designed to provide pandemic relief, noting that the legislature did not include “pandemic” or “illness” in the statutory scheme. The court also rejected WHA’s contention that federal disaster declarations should determine state property tax eligibility, holding that such federal circumstances are irrelevant to interpreting state tax statutes.

Key Takeaways

• COVID-19 does not satisfy the statutory definition of “natural disaster” for Washington property tax relief, which requires a physically destructive event originating in natural forces
• Courts interpret statutory terms consistently across related provisions; “natural disaster” maintains the same meaning throughout Title 84 property tax statutes
• Federal disaster declarations do not control the interpretation of state property tax statutes; each jurisdiction determines its own relief criteria
• Courts will not expand statutory language to reach policy outcomes; the legislature must explicitly include new categories of relief

Why It Matters

This decision has significant implications for hospitality and other pandemic-affected industries seeking state property tax relief. It establishes that even when federal authorities declare a major disaster and states access federal assistance, state property tax statutes do not automatically provide relief unless the underlying event fits the statutory definition. The ruling clarifies that property tax relief provisions—whether enacted for volcanic eruptions, earthquakes, or floods—are limited to physically destructive natural phenomena, not biological or health crises.

The decision also reinforces a principle of statutory interpretation: courts must respect the legislature’s choice of language and will not add categories the legislature omitted. For taxpayers and policymakers, the case demonstrates that pandemic-specific property tax relief requires legislative action rather than judicial expansion of existing “natural disaster” provisions.