Washington’s unlawful detainer statute (RCW 59.18.375) is held to violate due process insofar as it permits issuance of a writ of restitution without a court hearing if the landlord claims the right to evict based on non-payment of rent and the tenant fails to file a timely, sworn written statement disputing the amount allegedly owed.

Ninth Circuit Court of Appeals (Watford, J.); August 16, 2018; 2018 U.S. App. LEXIS 22784