Evictions

WEEKLY ROUNDUP FOR THE WEEK OF February 17, 2025

Washington Supreme Court:

Evictions – The CARES Act only requires 30 days’ notice when evicting a tenant for failure to pay rent, not evictions for other reasons, such as nuisance.  Hous. Auth. v. Knight, No. 102905-5 (February 20, 2025).

Division I:

U visas – Limiting cross-examination into a sexual assault victims’ pending U visa application may violate the defendant’s right to confront witnesses where the victim is the sole accuser and key witness.  State v. Bravo, No. 85030-0-I (February 18, 2025).

Division II:

Offender scoring – RCW 9.94A.525(1)(b), which excludes most juvenile adjudications from being included in a defendant’s offender score, does not apply to sentences imposed after the effective date for crimes committed before the effective date (July 23, 2023.)  State v. Solomon Gibson, No. 58962-1-II (February 19, 2025).

(Editor’s note: Division I has already made the same holding.  State v. Troutman, 30 Wn. App. 2d 592, 546 P.3d 458 (2024), review denied, 554 P.3d 1217 (Wash. 2024).  These holdings give effect to RCW 9.94A.345.)

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