Post 5081<\/span><\/strong><\/h3>\nSee the full video at https:\/\/rumble.com\/v6tq6qh-no-good-deed-goes-unpunished.html\u00a0<\/a> and at https:\/\/youtu.be\/wkbLjNjxfi4<\/a><\/p>\nInsured as Lessee is Obligated to Pay Rent<\/span><\/strong><\/h3>\n![\"\"](\"https:\/\/i0.wp.com\/zalma.com\/blog\/wp-content\/uploads\/2025\/05\/TEMPORARYHOUSING.png?resize=579%2C326\")
Joel Millar sued Anakka Hartwell, Liberty Insurance Corporation, and Temporary Housing, Inc. (THI) were sued after Hartwell, a policyholder of Liberty, failed to pay rent for a property Millar leased to her through THI. The court granted summary judgment in favor of THI and Liberty, dismissing Millar\u2019s claims, and Millar appealed the decision .<\/p>\n
In Joel Millar v. Anakka Hartwell, a Washington resident, Liberty Insurance Corporation, a foreign insurance corporation; and Temporary Housing, Inc. d\/b\/a CRS Temporary Housing, a foreign entity<\/em>, No. 85876-9-I, the Court of Appeals of Washington, Division 1 (May 19, 2025) resolved the dispute.<\/p>\nCase Overview<\/span><\/strong><\/h2>\nIn September 2018, Hartwell reported a water leak in her home and sought Additional Living Expense (ALE) coverage from Liberty for temporary housing. THI was appointed to assist Hartwell in finding temporary accommodation and placed Hartwell at a residence.<\/p>\n
\n- \n
Temporary Housing Arrangement:<\/span><\/strong><\/h3>\n<\/li>\n<\/ul>\nLiberty Insurance provides home insurance policies that include coverage for temporary housing after a covered loss. THI secured housing for Hartwell in a property owned by Millar, formalized through a Temporary Housing Confirmation. The lease was set from April 1, 2019, to June 30, 2019, with options for extensions.<\/p>\n
After the initial lease term, THI requested extensions, and Millar agreed. However, after confirming with Liberty that no further extensions would be granted, THI notified Millar that Hartwell was to vacate by November 8, 2019. Despite this, Hartwell remained in the property until December 2022, making some but not all rent payments .<\/p>\n
Legal Proceedings<\/span><\/strong><\/h2>\nMillar\u2019s lawsuit sought recovery of unpaid rent and included claims for breach of contract, misrepresentation, and violation of the Washington Consumer Protection Act (CPA). The trial court found no valid contract between Millar and THI or Liberty that would obligate them to continue paying rent after the lease termination date .<\/p>\n
The court granted THI and Liberty\u2019s motion for summary judgment, ruling that Millar\u2019s claims lacked sufficient evidence and that any agreement did not extend to indefinite rent payments.<\/p>\n
Millar appealed the summary judgment, arguing genuine issues of material fact regarding the existence of a contract and the duty of good faith and fair dealing.<\/p>\n
COURT\u2019S CONCLUSIONS<\/span><\/strong><\/h2>\nThe court concluded that:<\/p>\n
\n- The Confirmation did not establish a perpetual obligation for THI to pay rent beyond the specified lease period.<\/li>\n
- Millar acknowledged that the lease agreement was between himself and Hartwell, not involving THI or Liberty.<\/li>\n
- THI had provided the required notice before terminating payments, and thus, no breach occurred .<\/li>\n<\/ul>\n
Conclusion<\/span><\/strong><\/h2>\nThe appellate court affirmed the trial court\u2019s decision, dismissing all claims against THI and Liberty, thereby upholding the ruling that there was no enforceable contract obligating THI or Liberty to continue rent payments after the lease\u2019s termination date .<\/p>\n
Liberty, in accordance with its contract of insurance, found temporary housing for its insured while the damaged premises was repaired. It paid for a lease between the insured Hartwell and Millar for the period of reconstruction. The temporary lease expired and was extended with the agreement of Hartwell and Millar. Hartwell failed to pay all rent due so Millar sued the insurer with whom there was no contract. The good deeds of Liberty and THI arranging for the temporary housing was returned with a law suit even though they were not parties to the lease.<\/p>\n
![\"\"](\"https:\/\/i0.wp.com\/zalma.com\/blog\/wp-content\/uploads\/2024\/12\/BZTHEA.png?resize=300%2C282\")
(c) 2025 Barry Zalma & ClaimSchool, Inc.<\/p>\n
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Insured as Lessee is Obligated to Pay Rent<\/span><\/strong><\/h3>\nJoel Millar sued Anakka Hartwell, Liberty Insurance Corporation, and Temporary Housing, Inc. (THI) were sued after Hartwell, a policyholder of Liberty, failed to pay rent for a property Millar leased to her through THI. The court granted summary judgment in favor of THI and Liberty, dismissing Millar\u2019s claims, and Millar appealed the decision .<\/p>\n
In Joel Millar v. Anakka Hartwell, a Washington resident, Liberty Insurance Corporation, a foreign insurance corporation; and Temporary Housing, Inc. d\/b\/a CRS Temporary Housing, a foreign entity<\/em>, No. 85876-9-I, the Court of Appeals of Washington, Division 1 (May 19, 2025) resolved the dispute.<\/p>\nCase Overview<\/span><\/strong><\/h2>\nIn September 2018, Hartwell reported a water leak in her home and sought Additional Living Expense (ALE) coverage from Liberty for temporary housing. THI was appointed to assist Hartwell in finding temporary accommodation and placed Hartwell at a residence.<\/p>\n
\n- \n
Temporary Housing Arrangement:<\/span><\/strong><\/h3>\n<\/li>\n<\/ul>\nLiberty Insurance provides home insurance policies that include coverage for temporary housing after a covered loss. THI secured housing for Hartwell in a property owned by Millar, formalized through a Temporary Housing Confirmation. The lease was set from April 1, 2019, to June 30, 2019, with options for extensions.<\/p>\n
After the initial lease term, THI requested extensions, and Millar agreed. However, after confirming with Liberty that no further extensions would be granted, THI notified Millar that Hartwell was to vacate by November 8, 2019. Despite this, Hartwell remained in the property until December 2022, making some but not all rent payments .<\/p>\n
Legal Proceedings<\/span><\/strong><\/h2>\nMillar\u2019s lawsuit sought recovery of unpaid rent and included claims for breach of contract, misrepresentation, and violation of the Washington Consumer Protection Act (CPA). The trial court found no valid contract between Millar and THI or Liberty that would obligate them to continue paying rent after the lease termination date .<\/p>\n
The court granted THI and Liberty\u2019s motion for summary judgment, ruling that Millar\u2019s claims lacked sufficient evidence and that any agreement did not extend to indefinite rent payments.<\/p>\n
Millar appealed the summary judgment, arguing genuine issues of material fact regarding the existence of a contract and the duty of good faith and fair dealing.<\/p>\n
COURT\u2019S CONCLUSIONS<\/span><\/strong><\/h2>\nThe court concluded that:<\/p>\n
\n- The Confirmation did not establish a perpetual obligation for THI to pay rent beyond the specified lease period.<\/li>\n
- Millar acknowledged that the lease agreement was between himself and Hartwell, not involving THI or Liberty.<\/li>\n
- THI had provided the required notice before terminating payments, and thus, no breach occurred .<\/li>\n<\/ul>\n
Conclusion<\/span><\/strong><\/h2>\nThe appellate court affirmed the trial court\u2019s decision, dismissing all claims against THI and Liberty, thereby upholding the ruling that there was no enforceable contract obligating THI or Liberty to continue rent payments after the lease\u2019s termination date .<\/p>\n
Liberty, in accordance with its contract of insurance, found temporary housing for its insured while the damaged premises was repaired. It paid for a lease between the insured Hartwell and Millar for the period of reconstruction. The temporary lease expired and was extended with the agreement of Hartwell and Millar. Hartwell failed to pay all rent due so Millar sued the insurer with whom there was no contract. The good deeds of Liberty and THI arranging for the temporary housing was returned with a law suit even though they were not parties to the lease.<\/p>\n
(c) 2025 Barry Zalma & ClaimSchool, Inc.<\/p>\n
Please tell your friends and colleagues about this blog and the videos and let them subscribe to the blog and the videos.<\/p>\n
Subscribe to my substack at https:\/\/barryzalma.substack.com\/subscribe<\/a><\/p>\nGo to X @bzalma;\u00a0 Go to Barry Zalma videos at Rumble.com at https:\/\/rumble.com\/account\/content?type=all;<\/a> Go to Barry Zalma on YouTube- https:\/\/www.youtube.com\/channel\/UCysiZklEtxZsSF9DfC0Expg; Go to the Insurance Claims Library \u2013 <\/a>https:\/\/lnkd.in\/gwEYk<\/a><\/p>\n\nLike this:<\/h3>\n
Joel Millar sued Anakka Hartwell, Liberty Insurance Corporation, and Temporary Housing, Inc. (THI) were sued after Hartwell, a policyholder of Liberty, failed to pay rent for a property Millar leased to her through THI. The court granted summary judgment in favor of THI and Liberty, dismissing Millar\u2019s claims, and Millar appealed the decision .<\/p>\nCase Overview<\/span><\/strong><\/h2>\nIn September 2018, Hartwell reported a water leak in her home and sought Additional Living Expense (ALE) coverage from Liberty for temporary housing. THI was appointed to assist Hartwell in finding temporary accommodation and placed Hartwell at a residence.<\/p>\n
\n- \n
Temporary Housing Arrangement:<\/span><\/strong><\/h3>\n<\/li>\n<\/ul>\nLiberty Insurance provides home insurance policies that include coverage for temporary housing after a covered loss. THI secured housing for Hartwell in a property owned by Millar, formalized through a Temporary Housing Confirmation. The lease was set from April 1, 2019, to June 30, 2019, with options for extensions.<\/p>\n
After the initial lease term, THI requested extensions, and Millar agreed. However, after confirming with Liberty that no further extensions would be granted, THI notified Millar that Hartwell was to vacate by November 8, 2019. Despite this, Hartwell remained in the property until December 2022, making some but not all rent payments .<\/p>\n
Legal Proceedings<\/span><\/strong><\/h2>\nMillar\u2019s lawsuit sought recovery of unpaid rent and included claims for breach of contract, misrepresentation, and violation of the Washington Consumer Protection Act (CPA). The trial court found no valid contract between Millar and THI or Liberty that would obligate them to continue paying rent after the lease termination date .<\/p>\n
The court granted THI and Liberty\u2019s motion for summary judgment, ruling that Millar\u2019s claims lacked sufficient evidence and that any agreement did not extend to indefinite rent payments.<\/p>\n
Millar appealed the summary judgment, arguing genuine issues of material fact regarding the existence of a contract and the duty of good faith and fair dealing.<\/p>\n
COURT\u2019S CONCLUSIONS<\/span><\/strong><\/h2>\nThe court concluded that:<\/p>\n
\n- The Confirmation did not establish a perpetual obligation for THI to pay rent beyond the specified lease period.<\/li>\n
- Millar acknowledged that the lease agreement was between himself and Hartwell, not involving THI or Liberty.<\/li>\n
- THI had provided the required notice before terminating payments, and thus, no breach occurred .<\/li>\n<\/ul>\n
Conclusion<\/span><\/strong><\/h2>\nThe appellate court affirmed the trial court\u2019s decision, dismissing all claims against THI and Liberty, thereby upholding the ruling that there was no enforceable contract obligating THI or Liberty to continue rent payments after the lease\u2019s termination date .<\/p>\n
Liberty, in accordance with its contract of insurance, found temporary housing for its insured while the damaged premises was repaired. It paid for a lease between the insured Hartwell and Millar for the period of reconstruction. The temporary lease expired and was extended with the agreement of Hartwell and Millar. Hartwell failed to pay all rent due so Millar sued the insurer with whom there was no contract. The good deeds of Liberty and THI arranging for the temporary housing was returned with a law suit even though they were not parties to the lease.<\/p>\n
(c) 2025 Barry Zalma & ClaimSchool, Inc.<\/p>\n
Please tell your friends and colleagues about this blog and the videos and let them subscribe to the blog and the videos.<\/p>\n
Subscribe to my substack at https:\/\/barryzalma.substack.com\/subscribe<\/a><\/p>\nGo to X @bzalma;\u00a0 Go to Barry Zalma videos at Rumble.com at https:\/\/rumble.com\/account\/content?type=all;<\/a> Go to Barry Zalma on YouTube- https:\/\/www.youtube.com\/channel\/UCysiZklEtxZsSF9DfC0Expg; Go to the Insurance Claims Library \u2013 <\/a>https:\/\/lnkd.in\/gwEYk<\/a><\/p>\n\nLike this:<\/h3>\n
Temporary Housing Arrangement:<\/span><\/strong><\/h3>\n<\/li>\n<\/ul>\nLiberty Insurance provides home insurance policies that include coverage for temporary housing after a covered loss. THI secured housing for Hartwell in a property owned by Millar, formalized through a Temporary Housing Confirmation. The lease was set from April 1, 2019, to June 30, 2019, with options for extensions.<\/p>\n
After the initial lease term, THI requested extensions, and Millar agreed. However, after confirming with Liberty that no further extensions would be granted, THI notified Millar that Hartwell was to vacate by November 8, 2019. Despite this, Hartwell remained in the property until December 2022, making some but not all rent payments .<\/p>\n
Legal Proceedings<\/span><\/strong><\/h2>\nMillar\u2019s lawsuit sought recovery of unpaid rent and included claims for breach of contract, misrepresentation, and violation of the Washington Consumer Protection Act (CPA). The trial court found no valid contract between Millar and THI or Liberty that would obligate them to continue paying rent after the lease termination date .<\/p>\n
The court granted THI and Liberty\u2019s motion for summary judgment, ruling that Millar\u2019s claims lacked sufficient evidence and that any agreement did not extend to indefinite rent payments.<\/p>\n
Millar appealed the summary judgment, arguing genuine issues of material fact regarding the existence of a contract and the duty of good faith and fair dealing.<\/p>\n
COURT\u2019S CONCLUSIONS<\/span><\/strong><\/h2>\nThe court concluded that:<\/p>\n
\n- The Confirmation did not establish a perpetual obligation for THI to pay rent beyond the specified lease period.<\/li>\n
- Millar acknowledged that the lease agreement was between himself and Hartwell, not involving THI or Liberty.<\/li>\n
- THI had provided the required notice before terminating payments, and thus, no breach occurred .<\/li>\n<\/ul>\n
Conclusion<\/span><\/strong><\/h2>\nThe appellate court affirmed the trial court\u2019s decision, dismissing all claims against THI and Liberty, thereby upholding the ruling that there was no enforceable contract obligating THI or Liberty to continue rent payments after the lease\u2019s termination date .<\/p>\n
Liberty, in accordance with its contract of insurance, found temporary housing for its insured while the damaged premises was repaired. It paid for a lease between the insured Hartwell and Millar for the period of reconstruction. The temporary lease expired and was extended with the agreement of Hartwell and Millar. Hartwell failed to pay all rent due so Millar sued the insurer with whom there was no contract. The good deeds of Liberty and THI arranging for the temporary housing was returned with a law suit even though they were not parties to the lease.<\/p>\n
(c) 2025 Barry Zalma & ClaimSchool, Inc.<\/p>\n
Please tell your friends and colleagues about this blog and the videos and let them subscribe to the blog and the videos.<\/p>\n
Subscribe to my substack at https:\/\/barryzalma.substack.com\/subscribe<\/a><\/p>\nGo to X @bzalma;\u00a0 Go to Barry Zalma videos at Rumble.com at https:\/\/rumble.com\/account\/content?type=all;<\/a> Go to Barry Zalma on YouTube- https:\/\/www.youtube.com\/channel\/UCysiZklEtxZsSF9DfC0Expg; Go to the Insurance Claims Library \u2013 <\/a>https:\/\/lnkd.in\/gwEYk<\/a><\/p>\n\nLike this:<\/h3>\n
Millar\u2019s lawsuit sought recovery of unpaid rent and included claims for breach of contract, misrepresentation, and violation of the Washington Consumer Protection Act (CPA). The trial court found no valid contract between Millar and THI or Liberty that would obligate them to continue paying rent after the lease termination date .<\/p>\n
The court granted THI and Liberty\u2019s motion for summary judgment, ruling that Millar\u2019s claims lacked sufficient evidence and that any agreement did not extend to indefinite rent payments.<\/p>\n
Millar appealed the summary judgment, arguing genuine issues of material fact regarding the existence of a contract and the duty of good faith and fair dealing.<\/p>\n
COURT\u2019S CONCLUSIONS<\/span><\/strong><\/h2>\nThe court concluded that:<\/p>\n
\n- The Confirmation did not establish a perpetual obligation for THI to pay rent beyond the specified lease period.<\/li>\n
- Millar acknowledged that the lease agreement was between himself and Hartwell, not involving THI or Liberty.<\/li>\n
- THI had provided the required notice before terminating payments, and thus, no breach occurred .<\/li>\n<\/ul>\n
Conclusion<\/span><\/strong><\/h2>\nThe appellate court affirmed the trial court\u2019s decision, dismissing all claims against THI and Liberty, thereby upholding the ruling that there was no enforceable contract obligating THI or Liberty to continue rent payments after the lease\u2019s termination date .<\/p>\n
Liberty, in accordance with its contract of insurance, found temporary housing for its insured while the damaged premises was repaired. It paid for a lease between the insured Hartwell and Millar for the period of reconstruction. The temporary lease expired and was extended with the agreement of Hartwell and Millar. Hartwell failed to pay all rent due so Millar sued the insurer with whom there was no contract. The good deeds of Liberty and THI arranging for the temporary housing was returned with a law suit even though they were not parties to the lease.<\/p>\n
(c) 2025 Barry Zalma & ClaimSchool, Inc.<\/p>\n
Please tell your friends and colleagues about this blog and the videos and let them subscribe to the blog and the videos.<\/p>\n
Subscribe to my substack at https:\/\/barryzalma.substack.com\/subscribe<\/a><\/p>\nGo to X @bzalma;\u00a0 Go to Barry Zalma videos at Rumble.com at https:\/\/rumble.com\/account\/content?type=all;<\/a> Go to Barry Zalma on YouTube- https:\/\/www.youtube.com\/channel\/UCysiZklEtxZsSF9DfC0Expg; Go to the Insurance Claims Library \u2013 <\/a>https:\/\/lnkd.in\/gwEYk<\/a><\/p>\n\nLike this:<\/h3>\n
Conclusion<\/span><\/strong><\/h2>\nThe appellate court affirmed the trial court\u2019s decision, dismissing all claims against THI and Liberty, thereby upholding the ruling that there was no enforceable contract obligating THI or Liberty to continue rent payments after the lease\u2019s termination date .<\/p>\n
Liberty, in accordance with its contract of insurance, found temporary housing for its insured while the damaged premises was repaired. It paid for a lease between the insured Hartwell and Millar for the period of reconstruction. The temporary lease expired and was extended with the agreement of Hartwell and Millar. Hartwell failed to pay all rent due so Millar sued the insurer with whom there was no contract. The good deeds of Liberty and THI arranging for the temporary housing was returned with a law suit even though they were not parties to the lease.<\/p>\n
(c) 2025 Barry Zalma & ClaimSchool, Inc.<\/p>\n
Please tell your friends and colleagues about this blog and the videos and let them subscribe to the blog and the videos.<\/p>\n
Subscribe to my substack at https:\/\/barryzalma.substack.com\/subscribe<\/a><\/p>\nGo to X @bzalma;\u00a0 Go to Barry Zalma videos at Rumble.com at https:\/\/rumble.com\/account\/content?type=all;<\/a> Go to Barry Zalma on YouTube- https:\/\/www.youtube.com\/channel\/UCysiZklEtxZsSF9DfC0Expg; Go to the Insurance Claims Library \u2013 <\/a>https:\/\/lnkd.in\/gwEYk<\/a><\/p>\n\nLike this:<\/h3>\n
(c) 2025 Barry Zalma & ClaimSchool, Inc.<\/p>\nGo to X @bzalma;\u00a0 Go to Barry Zalma videos at Rumble.com at https:\/\/rumble.com\/account\/content?type=all;<\/a> Go to Barry Zalma on YouTube- https:\/\/www.youtube.com\/channel\/UCysiZklEtxZsSF9DfC0Expg; Go to the Insurance Claims Library \u2013 <\/a>https:\/\/lnkd.in\/gwEYk<\/a><\/p>\nLike this:<\/h3>\n