Palin Rp Investments-2, Llc, Resps V. Butterfield Assoc., Inc, Apps

Court of Appeals of Washington·Decided March 9, 2026·No. 87790-9·Unpublished

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

PALIN RP INVESTMENTS-2, LLC, a Washington Limited Liability No. 87790-9-I Company, and SKLP REAL ESTATE INVESTMENTS, LLC, a Washington DIVISION ONE Limited Liability Company, UNPUBLISHED OPINION

Respondents,

v.

BUTTERFIELD ASSOCIATES, INC., a Washington Corporation,

Defendant,

PROPERTY MANAGEMENT VA, LLC, a Washington Limited Liability Company,

Appellant.

DÍAZ, J. — Palin RP Investments-2, LLC and SKLP Real Estate Investments, LLC (together, Palin) are owners of a rental property who sued Property Management Vancouver Authority (PMVA) for breach of contract. Palin claimed that PMVA breached its contractual duty when it failed to pay the gas bill on the unoccupied property, resulting in water damage when a valve broke during a cold snap. A jury found in favor of Palin. PMVA moved for a new trial, arguing

that the court erred when it granted Palin’s motion in limine to exclude reference to the contract’s hold harmless provision. The court denied the motion for new trial, and PMVA raises the same argument on appeal. We affirm the trial court’s order.

I. BACKGROUND

In 2021, Palin hired Real Property Management Authority (Real Property), a business owned by Butterfield Associates, Inc. (Butterfield), to manage rental properties that Palin owned, including a property located in Vancouver, Washington. In the management agreement, which Real Property drafted, the section titled “Manager’s Obligations” gives Real Property inter alia the duty to “execute contracts for utilities and services for the operation, maintenance and safety of the property.”

In November 2022, PMVA bought Real Property from Butterfield and assumed the management obligations stated in the contract. PMVA did not pay the gas bill for the property. On December 7, 2022, NW Natural Gas disconnected the gas service to the property due to nonpayment. On December 25, a PMVA maintenance manager visited the property and saw water pouring out of the house from a broken valve underneath the sink of an upstairs bathroom.

Palin sued PMVA for damages and lost rent based inter alia on breach of contract. The trial began on October 21, 2024. During opening statements, PMVA stated that Palin had agreed “to hold the manager harmless from any damage in any suit . . . except in cases of willful misconduct or gross negligence.” This is language from the hold harmless provision in the management agreement.

Palin then moved in limine to exclude reference to the hold harmless provision. The court found that the hold harmless provision did not protect PMVA under these facts and granted Palin’s motion. The jury found in favor of Palin, awarding him $117,819.19 in damages. PMVA filed a motion for new trial, which the court denied. PMVA timely appeals.

II. ANALYSIS

PMVA claims that the court erred when it granted Palin’s motion in limine, both because the motion was untimely and because it is contrary to Washington law. We address each argument in turn. A. Timeliness PMVA claims that the court erred in granting Palin’s motion because the motion was untimely under its local rules and “deprived [PMVA] sufficient time to respond and to prepare their defense.” Palin argues that the court did not abuse its discretion because he filed the motion the day after he first became aware of PMVA’s intent to use the hold harmless provision as an affirmative defense, which itself was untimely. We agree with Palin.

A Clark County rule requires parties to bring all motions 10 court days before the hearing or trial. CLARK COUNTY SUPERIOR CT. LOCAL R. 6(d). The court, however, also has discretion to accept untimely materials. Zurich Servs. Corp. v. Gene Mace Constr., LLC, 26 Wn. App. 2d 10, 34, 526 P.3d 46 (2023). We review such rulings for an abuse of discretion. Clipse v. Com. Driver Servs., Inc., 189 Wn. App. 776, 786, 358 P.3d 464 (2015). “A court abuses its discretion when its decision is manifestly unreasonable or exercised on untenable grounds or for

untenable reasons.” Gildon v. Simon Prop. Grp., Inc., 158 Wn.2d 483, 494, 145 P.3d 1196 (2006) (citing Mayer v. Sto Indus., Inc., 156 Wash.2d 677, 684, 132 P.3d 115 (2006)).

The court should apply procedural rules “to foster and promote ‘the just, speedy, and inexpensive determination of every action.’” See Lybbert v. Grant County, 141 Wn.2d 29, 39, 1 P.3d 1124 (2000) (quoting CR 1(1)). “[W]henever possible, the rules of civil procedure should be applied in such a way that substance will prevail over form.” Griffith v. City of Bellevue, 130 Wn.2d 189, 192, 922 P.2d 83 (1996) (quoting First Fed. Sav. & Loan Ass’n v. Ekanger, 93 Wn.2d 777, 781, 613 P.2d 129 (1980)).

The trial court may waive court rules “when appropriate to protect a party's established right if the court ensures the waiver can be implemented in a manner that will adequately protect the rights of other parties who are affected.” Zurich Servs. Corp., 26 Wn. App. 2d at 31.

As to the established right in question here, plaintiffs have a right to protection from ambush of a delayed defense during litigation. King v. Snohomish County., 146 Wn.2d 420, 424, 47 P.3d 563 (2002) (citing Lybbert, 141 Wash.2d at 40). For this reason, parties must plead in advance any “‘matter constituting an avoidance or affirmative defense.’”1 Mahoney v. Tingley, 85 Wash.2d 95, 100, 529 P.2d 1068 (1975) (quoting CR 8(c)).

1 Palin characterizes the hold harmless clause as a “release” which must be affirmatively pled in advance pursuant to CR 8(c). Regardless of whether a hold harmless provision is a “release,” the legislature did not intend for list of affirmative defenses in CR 8(c) to be exhaustive, specifying that the defending party must also plead “any other matter constituting an avoidance or affirmative defense.”

An affirmative defense is a “defendant's assertion of facts and arguments that, if true, will defeat the plaintiff’s or prosecution’s claim, even if all the allegations in the complaint are true.” Defense, BLACK'S LAW DICTIONARY (12th ed. 2024). Pleading an affirmative defense is unnecessary “if the defense does not raise any new issues.” Hedger v. Groeschell, 199 Wn. App. 8, 16, 397 P.3d 154 (2017) (citing Shinn Irrig. Equip., Inc. v. Marchand, 1 Wn. App. 428, 430-31, 462 P.2d 571 (1969)). “Any matter that does not tend to controvert the opposing party’s prima facie case as determined by applicable substantive law should be pleaded.” Harting v. Barton, 101 Wn. App. 954, 962, 6 P.3d 91 (2000) (quoting Shinn Irrig., 1 Wn. App. at 430-31.).

Both state and federal courts have held that a defense that seeks to avoid liability but does not dispute the facts alleged by the plaintiff—such as a hold harmless defense, release of liability, or exculpatory provision—raises a new issue and therefore must be pled in advance. See, e.g., Deep Photonics Corp. v. LaChapelle, 303 Or. App. 699, 719, 466 P.3d 660 (2020), aff'd, 368 Or. 274, 491 P.3d 60 (2021) (finding that because defendants “waited through discovery, through summary judgment, and even through plaintiffs’ presentation of evidence at trial, . . . it was simply too late to plead an affirmative defense”); Siegemund v. Shapland, 324 F. Supp. 2d 176, 183-85 (D. Me. 2004) (sanctioning defendant who “would have been wise to plead the defense affirmatively”). 2

2 Unlike in Siegemund, PMVA did not move to amend its answer. And, unlike in other federal cases, we hold applicability of “the pertinent provision was [not] ‘evident’ in the contract,” or in any other action taken by the parties, which may have obviated the need to affirmatively “invoke an exculpatory provision.” Core Commc’ns, Inc. v. Verizon Maryland LLC, 744 F.3d 310, 321 (4th Cir. 2014).

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