Princeton Property Management Lawsuit: Ruling and 2025 Amendment

The Princeton Property Management lawsuit ended with a Washington Court of Appeals ruling that eviction settlement agreements are void and unenforceable when they require tenants to give up rights protected by the state’s Residential Landlord-Tenant Act. Decided June 11, 2024, Princeton Property Management, Inc. v. Allen upended a routine practice: landlords and tenants across Washington had long resolved unlawful detainer cases through negotiated agreements that waived procedural protections, and the court held that state law forbids exactly that.¹

What the Court Held

A three-judge panel of Division 2 unanimously reversed a Clark County Superior Court decision that had treated the parties’ settlement as binding. Writing for the panel, Judge Erik Price grounded the ruling in RCW 59.18.230(1)(b), an anti-waiver provision enacted as part of a 2021 tenant-protection package. The statute provides that any agreement entered into during an unlawful detainer action that waives tenant rights under the Residential Landlord-Tenant Act is “void and unenforceable.”²

The settlement at issue contained a clause stating that “the parties forego the usual unlawful detainer procedures” and allowed the landlord to obtain an immediate writ of restitution on any breach. The court found that language could not be reconciled with the RLTA and described the statute’s reach as “sweeping in its scope.”¹

Because the agreement violated the anti-waiver rule, the court declared it void from the start. That meant it was never legally valid, could not be ratified, and could not be enforced. The panel remanded the case with instructions to restore the parties to the position they held before the agreement existed, and it noted that the ruling applies regardless of whether the tenant had a lawyer when signing.¹

Which Tenant Rights Cannot Be Waived

The court identified the specific protections the settlement had stripped away. Under the RLTA, a tenant facing eviction for nonpayment is entitled to:

A 14-day pay-or-vacate notice before eviction for unpaid rent.
The right to cure by paying what is owed.
The right to unilaterally reinstate a tenancy by paying amounts due after a notice expires but before the court enters judgment.
The right to request a court-ordered repayment plan.
The right to mediate disputes over unpaid rent.
A show cause hearing at which the landlord must prove its case by a preponderance of the evidence, rather than obtaining a writ based solely on an alleged breach of a settlement.³

Princeton had argued that RCW 59.18.360, which lets landlords and tenants exempt themselves from certain notice requirements tied to general tenant duties, saved the deal. The court disagreed and held that the narrow exemption did not extend to the broad procedural and substantive rights the tenants had given up.¹

How the Case Reached the Appeals Court

Princeton Property Management managed Evergreen Village Apartments in Vancouver, Washington, where Kathleen Allen and her daughter Aaron Allen, both of whom had disabilities, were tenants. In October 2022, Princeton inspected the apartment and issued a three-day notice to quit alleging the unit was “grossly unsanitary.” The Northwest Justice Project, which later represented the Allens, said the inspection occurred while Kathleen was hospitalized and Aaron was recovering from surgery.⁴

Before a hearing, the parties signed a CR 2A settlement. The Allens agreed to clean the apartment, submit to inspections, pay past-due rent for November 2022 through February 2023 by February 13, 2023, and pay future rent by the sixth of each month. In February 2023, the Allens submitted their rent one day late. Aaron Allen said the delay followed her mother’s hospitalization and a death in the family. Princeton rejected the payment and moved for an immediate writ of restitution.¹

The superior court treated the settlement as valid at every stage. It issued a writ, later granted a motion to vacate on procedural grounds while keeping a stay in place, and in April 2023 found the Allens had breached the agreement by failing to address property repairs. A new writ issued, and the sheriff removed them from the apartment.¹ Kathleen Allen died days after the May 7, 2024, oral argument on appeal, while still homeless. As of July 2024, Aaron Allen remained homeless, and the eviction had cost the family its housing voucher.⁵

What the Ruling Changes for Landlords and Tenants

Most Washington evictions never reach a full merits hearing. They resolve through private settlement agreements, often signed under time pressure by tenants who may or may not have counsel. The Princeton ruling calls into question the enforceability of settlements that follow the old template.⁴

For tenants, the practical effect is that a signature on an eviction settlement does not extinguish core RLTA protections. If a landlord seeks to enforce an agreement by obtaining an immediate writ on a breach, the tenant can point to Princeton and RCW 59.18.230(1)(b) to argue the waiver is void. The panel noted its holding applies whether or not the tenant was represented by counsel.¹

For landlords, the ruling means settlement agreements need to be rewritten to preserve the tenant’s statutory rights: the 14-day notice, the opportunity to cure, access to mediation and repayment plans, and a merits hearing before a writ issues. Princeton’s counsel reported that some landlords were avoiding settlement agreements altogether because of the legal uncertainty, and industry representatives warned the decision could push more cases into formal court proceedings.⁶ An amicus brief from attorney Peter S. Schweda argued that settlement agreements often benefit tenants by providing delayed move-out dates or keeping evictions off public records, and that treating them as waivers would chill negotiation.⁷

The panel acknowledged the tension and said it was not the court’s to resolve. Policy arguments about the utility of eviction settlements, it said, belong before the legislature.⁴

Reconsideration and Constitutional Challenge

Princeton moved for reconsideration and argued that the 2021 anti-waiver law is vague and unconstitutional and that it violates the Contract Clause of the U.S. and Washington Constitutions. The company signaled it would seek review from the Washington Supreme Court if reconsideration was denied.⁸

The Allens’ response argued that Princeton had not raised the constitutional claims at the trial level or in merits briefing and had not given the mandatory notice to the state Attorney General required when a party challenges a statute’s constitutionality. On the substance, their attorneys argued the Contract Clause was not implicated because the settlement was signed in February 2023, well after the anti-waiver statute took effect in April 2021, and that the statute clearly put landlords on notice that agreements waiving RLTA rights are void.³

The 2025 Legislative Amendment

During the 2025 session, the Washington legislature amended RCW 59.18.230 through Senate Bill 5313, updating the list of prohibited and unenforceable provisions in rental agreements. The bill added prohibitions on clauses waiving the right to pursue class action lawsuits, mandatory nondisclosure agreements, and certain mandatory arbitration clauses. The amendment applies to leases entered into or renewed on or after July 27, 2025.⁹¹⁰ The available legislative record does not indicate whether SB 5313 was passed in direct response to Princeton, though it amends the same statutory section the court applied.

1
FindLaw. Princeton Property Management Inc v Allen
2
Washington State Legislature. RCW 59.18.230
3
Washington State Courts. Answer to Petition for Review, Princeton Property Management Inc v Allen
4
Northwest Justice Project. Court of Appeals Rules Eviction Settlement Agreement Void and Unenforceable
5
Northwest Justice Project. Princeton Property Management v Allen Ruling
6
Washington State Standard. Court Fight Tests WAs Protections for Tenants Threatened With Eviction
7
Washington State Courts. Amicus Brief of Peter S Schweda, Princeton Property Management Inc v Allen
8
The Spokesman-Review. Court Fight Tests WAs Protections for Tenants Threatened With Eviction
9
Washington State Legislature. RCW 59.18.230
10
City of Olympia. Legal Update for Tenant Protections