Paula Ramsum v. Walter Frenzel

MEMORANDUM

Paula Ramsum appeals the district court decision dismissing her action fpr judicial foreclosure against property in Whatcom County, Washington, that was formerly owned by her ex-husband.

We review de novo dismissals under Fed.R.Civ.P. 12(b)(6). Wilson v. Hewlett-Packard Co., 668 F.3d 1136, 1140 (9th Cir.2012). In light of the Washington statutes at issue in this case, we affirm. See Wash. Rev.Code §§ 4.64.030, 65.04.045, 65.04.047, 26.18.020, 26.18.055, 26.21.480, 26.21.490. Because Ramsum did not identify or describe her ex-husband’s former property in the documents she filed with the Whatcom County Auditor’s Office, she did not substantially comply with the requirements for recording liens against real property. See Kim v. Lee, 102 Wash.App.586, 9 P.3d 245, 249 (2000), rev’d on other grounds, 145 Wash.2d 79 , 31 P.3d 665 (2001) (en banc) (“Washington courts have long upheld actions taken in substantial compliance with statutory requirements, albeit with procedural imperfections. Substantial compliance requires ‘actual compliance in respect to the substance essential to every reasonable objective of [the] statute.’ ” (quoting City of Seattle v. Pub. Emp’t Relations…