Western Plaza, LLC v. Tison

¶34 (dissenting) — I agree with the majority that a rent cap provision is not prohibited by the Manufactured/ Mobile Home Landlord-Tenant Act (MHLTA), chapter 59.20 RCW. I also agree that the MHLTA allows a landlord to increase rent with proper notice and procedures. However, I depart from the majority in its disregard of the statute of frauds for the purpose of reaching a particular result in this case. Nothing in the MHLTA creates or implies an exemption from the statute of frauds, which applies to leases of real property. Because Norma Tison’s lease does not comply with the statute of…