<!doctype html>
<html>
<head>
<meta charset="UTF-8">
</head>
<body>
<div class="default-style">
Happy Friday. Deadbeat tenant brings tort claim against landlord. Setting aside the issue of retaliation, may LL bring a counterclaim for unlawful detainer? I am aware of the Munden v. Hazelrigg, 105 Wn.2d 39 (1985) line of cases, but those seem to apply when tenant brings the counterclaim. Although unlawful detainer is a summary proceeding, if LL were to bring an unlawful detainer as a counterclaim it would only go to the remedy at the end of the case. I suppose a separate UD action could be brought and consolidated with the tort action, but that would not be efficient. Thoughts?
</div>
<div class="io-ox-signature">
<p>Scott G. Thomas<br><br><br><br></p>
</div>
</body>
</html>