(dissenting) — The Real Estate Contract Forfeiture Act (RCW 61.30) confers standing to set aside a forfeiture upon the person who, at the time the notice of intent to forfeit is recorded, is the last holder of a purchaser's interest in a real estate contract. RCW 61.30.140(2). The majority concludes that the statute is unambiguous in that it does not extend standing to an assignee who receives an assignment of the purchaser's interest after the notice of intent to forfeit is recorded. I disagree.
This statute is ambiguous when read in the context of the law of assignments. An assignee of a contract who receives full title and interest stands in the shoes of his assignor. Moore v. Moore, 20 Wn. App. 909, 912, 583 P.2d 1249 (1978). Schultz received an effective and apparently irrevocable assignment and delegation of Snook's rights and obligations under the real estate contract. It follows that Schultz has the same right that Snook had to challenge the forfeiture.
The majority argues that Snook could not have transferred this right to challenge a forfeiture because the right is conferred by statute, not by contract. This argument contains the untenable assumption that a transfer of contract rights does not transfer the statutory rights that pertain to that contract. If this assumption were correct, an assignee could not assert the statutory period of limitations as a bar to litigation if the contract lacked its own limitations provision. Here, in the absence of a specific statutory preclusion, I believe that Schultz steps into the shoes of Snook and, thereby, can challenge the forfeiture.
*456Since this statute is amenable to more than one interpretation, it should be interpreted in the manner most consistent with the Legislature's intent. See Stewart Carpet Serv., Inc. v. Contractors Bonding & Ins. Co., 105 Wn.2d 353, 358, 715 P.2d 115 (1986). Ambiguous statutes should be interpreted in a reasonable manner. Human Rights Comm'n v. Cheney Sch. Dist. 30, 97 Wn.2d 118, 121, 641 P.2d 163 (1982).
Construing the statute as conferring standing upon Schultz is consistent with the statute's goal of balancing the rights of the buyer and the seller. See Hume, The Washington Real Estate Contract Forfeiture Act, 61 Wash. L. Rev. 803, 804 (1986). For example, the act's notice provisions protect both the buyer and the seller. In the case of the seller, the statute assures that if the seller follows the notice procedures, he will not have to defend against subsequent successors in interest who attempt to set aside a forfeiture on the grounds that they did not receive notice. Here, it does not impinge on this protection to extend Schultz standing. Schultz does not argue that there was a failure of notice. He merely asks that the seller deal with him on the same terms as she would have dealt with the assignor.
Further, a statute will not be subject to a literal interpretation if it would result in strained or absurd results. State v. Keller, 98 Wn.2d 725, 728, 657 P.2d 1384 (1983). One absurd result of the majority's interpretation is that some declarations of forfeiture will go unchallenged. For example, an assignor has lost standing to enforce the contract because an absolute and unconditional assignment extinguishes the assignor's right to performance of and interest in the contract. See Wymer v. Wymer, 16 Bankr. 497, 505 (Bankr. 9th Cir. 1980); Aaron Ferer & Sons Ltd. v. Chase Manhattan Bank, N.A., 731 F.2d 112, 125 (2d Cir. 1984); 4 A. Corbin, Contracts § 891 (1951 & Supp. 1990). Lacking such standing, the assignor has little or no incentive to challenge a forfeiture because a forfeiture relieves an assignor of most of the contract obligations for which he is *457secondarily liable. See RCW 61.30.100.2 Moreover, the assignee could not challenge the forfeiture if he received the assignment after the notice of intent to forfeit was given to the assignor. Therefore, the forfeiture would go unchallenged. Importantly, Washington disfavors forfeitures. Markland v. Wheeldon, 29 Wn. App. 517, 520, 629 P.2d 921, review denied, 96 Wn.2d 1018 (1981).
The majority attempts to minimize the importance of this problem by noting that an action to set aside a declaration of forfeiture is only one of several remedies. It states that it is possible that Schultz was within the class of guarantors, sureties and lienholders who might have had the right to cure the default and enjoin the forfeiture pursuant to RCW 61.30.090(2) and RCW 61.30.110(2). However, Schultz was not a guarantor, surety, or lienholder; therefore, under the majority's interpretation of the statute, he could not have cured the default nor enjoined the forfeiture.
Another absurd consequence is that if a vendee received a notice of intent to forfeit and then died, no one would have standing to challenge the declaration of forfeiture. The majority dismisses this potential consequence by stating that RCW 61.30.010(7) extends the definition of "purchaser" to include a personal representative in a probate proceeding. However, under the majority's interpretation of the statute, the personal representative must be the last holder of a purchaser's interest at the time the notice is recorded in order for that personal representative to have standing.
*458The majority necessarily implies that the personal representative can step into the shoes of the decedent and, thereby, challenge the forfeiture. Similarly, an assignee necessarily has standing to challenge a forfeiture because he steps into the shoes of the assignor.
I would reverse and remand for trial.
Review denied at 116 Wn.2d 1027 (1991).
"Effect of forfeiture.
"(4) After the declaration of forfeiture is recorded, the seller shall have no claim against and the purchaser shall not be liable to the seller for any portion of the purchase price unpaid or for any other breach of the purchaser's obligations under the contract, except for damages caused by waste to the property to the extent such waste results in the fair market value of the property on the date the declaration of forfeiture is recorded being less than the unpaid monetary obligations under the contract and all liens or contracts having priority over the seller's interest in the property." RCW 61.30.100.