Tsigereda Teklu, V. Djamshid Setayesh

CourtCourt of Appeals of Washington
DecidedFebruary 28, 2022
Docket82649-2
StatusPublished
Cited by1 cases

This text of Tsigereda Teklu, V. Djamshid Setayesh (Tsigereda Teklu, V. Djamshid Setayesh) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tsigereda Teklu, V. Djamshid Setayesh, (Wash. Ct. App. 2022).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

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IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE TSIGEREDA TEKLU, ) No. 82649-2-I ) Respondent, ) ) v. ) ) DJAMSHID SETAYESH, ) PUBLISHED OPINION ) Appellant. ) )

VERELLEN, J. — The general rule in Washington “subject to some

exceptions and qualifications” is that a document that transfers an interest in land

must contain a legal description to satisfy the statute of frauds. But one

recognized exception to Washington’s strict legal description requirement is

reference to an assessor’s tax parcel number. Specifically, if a document

transferring an interest in land contains the tax parcel number and the county in

which the property is located, that reference is sufficient to satisfy the statute of

frauds if the tax parcel number refers a person of “ordinary intelligence” to records

on file in the county assessor’s office or in turn to documents on record with the

county auditor containing the complete legal description. Such a reference to the

tax parcel number and county “furnishes the legal description of the real property For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 82649-2-I/2

involved with sufficient definiteness and certainty to meet the requirements of the

statute of frauds.”1

Here, because the purchase and sale agreement that Djamshid Setayesh

entered into with Tsigereda Teklu contained the tax parcel number and the county

in which the property was located, the agreement referred a person of ordinary

intelligence to the property account summary containing the “sales history table”

on file in the Snohomish County assessor’s office, which in turn referred such a

person to the complete legal description in the six most recent deeds to the

property on record with the Snohomish County auditor. Here, the inclusion of the

tax parcel number coupled with the county in which the property was located

satisfied the legal description requirement of the statute of frauds.

Therefore, we affirm.

FACTS

Djamshid Setayesh owned a parcel of real property in Lynnwood,

Washington. On October 7, 2015, Setayesh entered into a lease agreement, a

purchase and sale agreement, and an option to purchase agreement with

Tsigereda Teklu. The agreements provided Teklu with a five-year lease and an

option to purchase the property “on or before October 2020.”2

The property was identified in the purchase and sale agreement as Tax

Parcel No. 27041700100700 (Snohomish County), 6416 180th Street SW

1 Bingham v. Sherfey, 38 Wn.2d 886, 889, 234 P.2d 489 (1951).

2 Clerk’s Papers (CP) at 140, 143.

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 82649-2-I/3

Lynnwood, Washington, 98037. The agreement also provided that the legal

description was “Attached as Exhibit A,”3 but there was no Exhibit A attached.

On September 4, 2019, Teklu exercised the option. Setayesh refused to

sell Teklu the property. Teklu brought an action for specific performance against

Setayesh.

About a year later, Teklu filed a summary judgment motion. Teklu argued

that either she was entitled to specific performance by the terms of the purchase

and sale agreement or, in the alternative, based upon part performance. Setayesh

responded that the purchase and sale agreement was unenforceable for failure to

contain an adequate legal description of the property and that Teklu could not

establish her claim of part performance as a matter of law.

The court granted Teklu’s summary judgment motion. Setayesh filed a

motion for reconsideration, arguing that Teklu failed to proffer adequate evidence

to support her claim that using the tax parcel number in a county records search

would reveal documents containing a complete legal description of the property.

The court granted Setayesh’s motion for reconsideration and vacated its initial

order.

The next year, Teklu filed a second summary judgment motion, explaining

step-by-step how a person could enter the tax parcel number into the assessor’s

website and find the assessor’s property account summary with an abbreviated

legal description, together with a sales history table referencing the documents on

3 CP at 128.

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/. No. 82649-2-I/4

file with the county auditor, including the six most recent deeds to the property

containing a complete legal description. Setayesh filed a cross motion for

summary judgment, again arguing that the purchase and sale agreement failed to

comply with the legal description requirement of the statute of frauds and that

Teklu did not establish part performance.

On April 23, 2021, in separate orders, the trial court granted Teklu’s

summary judgment motion and denied Setayesh’s cross motion for summary

judgment. The court concluded the purchase and sale agreement satisfied the

statute of frauds because the tax parcel number coupled with the county in which

the property was located constituted a sufficient legal description. The court also

granted Teklu attorney fees and costs.

Setayesh appeals.

ANALYSIS

I. Statute of Frauds

Setayesh argues that the trial court erred in granting Teklu specific

performance of the purchase and sale agreement because the agreement did not

contain a legal description required by the statute of frauds.

We review an order granting summary judgment de novo.4 “Summary

judgment is proper only when there are no genuine issues of material fact and the

4 Marina Condo. Homeowner’s Ass’n v. Stratford at Marina, LLC, 161 Wn.

App. 249, 255, 254 P.3d 827 (2011) (citing Hadley v.

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