Laffranchi v. Lim

¶1 This case presents the question of whether a tenant in possession of a residence following the sale of his landlord’s interest in it at a nonjudicial foreclosure sale is a necessary party to an unlawful detainer proceeding brought by the purchaser to obtain possession. We hold that the trial court lacked subject matter jurisdiction because a necessary party, a tenant in possession, was not made a party, and we reverse and remand for further proceedings as set forth below.

FACTS

¶2 Steven DeVore leased a four-bedroom house from Oscar Lim in the city of Snohomish in November 2006. The parties’…