Revised Code of Washington
Wash. Rev. Code § 59.18.080 (2026)
✓ current as of May 2026
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The tenant shall be current in the payment of rent including all utilities which the tenant has agreed in the rental agreement to pay before exercising any of the remedies accorded him or her under the provisions of this chapter: PROVIDED, That this section shall not be construed as limiting the tenant's civil remedies for negligent or intentional damages: PROVIDED FURTHER, That this section shall not be construed as limiting the tenant's right in an unlawful detainer proceeding to raise the defense that there is no rent due and owing.
Notes of Decisions
Cited in 10
cases (5 in the last 5 years), 1985–2025 · leading case: Pham v. Corbett, 351 P.3d 214 (Wash. Ct. App. 2015).
Pham v. Corbett, 351 P.3d 214 (Wash. Ct. App. 2015). “¶42 Pham argues that the Tenants were barred by RCW 59.18.080 from exercising remedies under the RLTA because they were not current in rent.”
Gonzales v. Inslee, 535 P.3d 864 (Wash. 2023). “Most specifically, the petitioners point to the tenants’ obligation to pay rent under RCW 59.18.080 and RCW 59.18.130. Appellants’ Suppl.”
State v. Schwab, 693 P.2d 108 (Wash. 1985). “See RCW 59.18.080. Requiring a low-income tenant to be current in rent undoubtedly deprives many such tenants of the remedial provisions of the Act.”
Jammeh v. HNN Assocs. LLC (W.D. Wash. 2020). “at 13-14 (citing RCW 59.18.080 (stating 6 that a tenant must be “current in the payment of rent including all utilities which the 7 tenant has agreed in the rental agreement to pay before exercising any of the remedies” 8 under the RLTA)).”
Rental Hous. Assoc., App/x-resps V. City Of Seattle, Resp/x-app (Wash. Ct. App. 2022). “RCW 59.18.080. But RCW 59.18.080, by its language, applies only to a tenant’s remedies under the RLTA, not to remedies or defenses arising from other laws or ordinances.”
Arthur Skinner, Res/cross-app V. Incity Props. Holdings Inc, App/cross-res (Wash. Ct. App. 2025). “4 RCW 59.18.080. Under the landlords’ reasoning, even after establishing forcible detainer, a residential tenant would need to be current in rent to be able to obtain possession, actual damages, and reasonable attorney fees.”
Lang Pham v. Shawn Corbett (Wash. Ct. App. 2015). “Pham argues that the Tenants were barred by RCW 59.18.080 from exercising remedies under the RLTA because they were not current in rent.”
Eight Is Enough, Llc, V. Cynthia Ohlig (Wash. Ct. App. 2024). “This claim relies on statutory language that “[t]he tenant shall be current in the payment of rent including all utilities which the tenant has agreed in the rental agreement to pay before exercising any of the remedies accorded him or her under the provisions of this chapter[.”
Arthur Skinner, Res/cross-app V. Incity Props. Holdings Inc, App/cross-res (Wash. Ct. App. 2025). “4 RCW 59.18.080. Under the landlords’ reasoning, even after establishing forcible detainer, a residential tenant would need to be current in rent to be able to obtain possession, actual damages, and reasonable attorney fees.”
Wayne R. Richardson v. Coast Realestate Servs. (Wash. Ct. App. 2015). “On May 20, Defendants filed a motion for summary judgment arguing that Richardson's failure to pay rent under RCW 59.18.080 bars his lawsuit.2 A hearing on the motion was noted for June 20.”
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