Victoria Lockett v. Douglas Saturno

CourtCourt of Appeals of Washington
DecidedMarch 1, 2022
Docket38046-7
StatusPublished
Cited by1 cases

This text of Victoria Lockett v. Douglas Saturno (Victoria Lockett v. Douglas Saturno) 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
Victoria Lockett v. Douglas Saturno, (Wash. Ct. App. 2022).

Opinion

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FILED MARCH 1, 2022 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

VICTORIA LOCKETT, ) ) No. 38046-7-III Appellant, ) ) v. ) ) DOUGLAS SATURNO, ) PUBLISHED OPINION ) Respondent. )

STAAB, J. — Victoria Lockett and her family were qualified for a Section 8

Housing Voucher valued at $1043 per month. Douglas Saturno advertised a rental unit

for $995 per month. When Ms. Lockett met Mr. Saturno to view the rental, he asked

about her “source of income” and then told her that her voucher would not cover the

monthly rental. Ms. Locket did not fill out a written rental application. Instead, she filed

suit against Mr. Saturno for “source-of-income” discrimination under RCW 59.18.255.

At summary judgment, the trial court dismissed Ms. Lockett’s complaint after concluding

that she did not qualify as an “otherwise eligible prospective tenant” because she did not

submit a written rental application.

The term “prospective tenant” is defined as one who “has applied for” a rental

unit. RCW 59.18.030(25). As a matter of first impression, we hold that the term “has

applied for” should be given a broad definition that includes a person who requests to be For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 38046-7-III Lockett v. Saturno

considered for, or expresses serious interest in a rental unit. Because Ms. Lockett meets

this definition, she was a prospective tenant.

Alternatively, Mr. Saturno asserts that Ms. Lockett cannot show that she was

“otherwise eligible” because she failed to submit a written application and thus, her

qualifications were unknown. By statute, Mr. Saturno must provide or post his eligibility

criteria before obtaining any information about a prospective tenant. On remand, the trial

court must determine whether Ms. Lockett is otherwise eligible based on the rental

criteria posted by Mr. Saturno in compliance with RCW 59.l8.255(1).

We reverse the trial court’s order on summary judgment dismissing Ms. Lockett’s

complaint and remand for proceedings consistent with this opinion.

BACKGROUND

We consider the following facts in a light most favorable to Victoria Lockett as the

nonmoving party. Keck v. Collins, 184 Wn.2d 358, 370, 357 P.3d 1080 (2015).

Ms. Lockett’s household received a federal Housing Choice Voucher Program

Section 8 (voucher) valued at $1043 per month, qualifying them for a two-bedroom rental

unit. Her household consists of Ms. Lockett, her minor child, and her partner Oliver Neal

who is disabled and receiving SSI (supplemental security income) benefits.

Ms. Lockett contacted Lori Sharp, a rental agent, who referred her to Douglas

Saturno because he had a two-bedroom rental house available to lease for $995 per month

plus utilities. Ms. Lockett set up an appointment with Mr. Saturno and met him at the

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

rental unit. As Ms. Lockett and Mr. Saturno approached the rental unit, Mr. Saturno

asked about her income and employment. Ms. Lockett told Mr. Saturno about the family

voucher, Mr. Neal’s SSI, and their status as full-time college students. After hearing this

information, Mr. Saturno stopped and told Ms. Lockett that “the housing voucher would

not cover this house.” Clerk’s Papers (CP) at 39. He continued stating that she was free

to look at the rental unit but seemed hesitant to allow her to enter. Once inside the house,

Ms. Lockett asked why the housing voucher would not cover the home and whether the

home had deficiencies. Mr. Saturno clarified that the voucher would not cover the house

because the rent was too high. He then asked if Ms. Lockett and Mr. Neal were married.

When Ms. Lockett responded that they were not, he told her they could not apply for the

house on two separate vouchers. She explained to him that there was one voucher for her

three-person family. Mr. Saturno reasserted that her voucher “would not cover the house

either way.” CP at 40. Mr. Saturno claims that he advised them that they needed to

make a formal application with a fee.

Ms. Lockett and her partner left the house and contacted Lori Sharp by text

message to reassure her that they had one voucher for their family. At the same time, Mr.

Saturno sent a message to Ms. Sharp indicating Ms. Lockett had two separate vouchers.

The rental agent considered Ms. Lockett’s financial situation “borderline.” CP at 51.

Ms. Lockett sued Mr. Saturno for source-of-income discrimination under RCW

59.18.255. Mr. Saturno moved to dismiss her complaint on summary judgment, asserting

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

that Ms. Lockett was not “an otherwise eligible prospective tenant” under RCW

59.18.255(1) because she failed to submit a written application for consideration. In

support of his motion, Mr. Saturno acknowledged that Ms. Sharp handled his tenant

screening and applications. If an applicant was successfully screened, they could submit

an online application. Mr. Saturno asserted that neither Ms. Lockett nor Mr. Neal were

screened or submitted an online application for the rental unit. The screening process for

his rental properties generally involves “various criteria” concerning criminal history

checks, rental history, credit history, and income requirements. Mr. Saturno’s specific

“various criteria” are not provided in the record.

Ms.

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