Pacific Northwest Group a v. Pizza Blends, Inc.

(concurring) — I agree with the disposition of this matter. I write separately to focus on the question of the enforceability of clauses prohibiting oral modifications of leases.

In this case, we apply Washington’s common law of contracts to a commercial lease of realty to determine that the lease provision prohibiting oral modifications is unenforceable.3 While that is the correct result in this case, I caution that this application of a contract principle to a lease of realty should not signal indiscriminate application of all contract principles to leases of realty.

One widely-respected…