Eastwood v. Horse Harbor Foundation, Inc., et al., 170 Wash. 2d 380, 241 P.3d 1256 (2010)

(landlord sued tenant for commission of waste on leased property; court finds that duty to not commit waste is a tort duty that is independent of the lease agreement; thus, commission of waste does not limit landlord’s recovery to breach of lease agreement; court found evidence of proximate cause and directors of corporation for which tenant worked individually liable for gross negligence in permitting waste).