HOUSING AUTHORITY OF CITY OF EVERETT v. Terry

— Respondent Housing Authority of the City of Everett brought an unlawful detainer action under our landlord and tenant act, RCW Title 59, against Appellant Ray Terry, a mentally handicapped person, for breach of a lease covenant by creating a "threat to the health and safety of other residents" of the housing complex. But respondent did not comply with the notice provisions of RCW 59.12.030(4) which require a 10-day opportunity to comply with a breached covenant in a lease. The trial court ruled that federal law preempts the Washington statutory notice requirements.

We hold that there is no…