Justia Landlord - Tenant Opinion Summaries

Articles Posted in Minnesota Supreme Court
by
The Supreme Court affirmed the opinion of the court of appeals reversing the judgment of the district court refusing to send the underlying rent dispute to arbitration and resolving the claim itself, holding that the dispute should be sent to arbitration.Landlord entered into a lease with Tenant providing that if Tenant defaulted Landlord shall submit such dispute to binding arbitration. When a dispute arose over water damage and withheld rent, litigation and arbitration resulted, with an arbitrator awarding judgment for Tenant. Thereafter, the trustee for several entities that held mortgages on the building brought a foreclosure action against Owner and appointed Receiver. When Tenant continued to refuse to pay rent, Receiver brought suit, and Tenant sought to send the dispute to arbitration. At issue was whether Receiver was bound by the lease's arbitration clause. The district court refused to send the dispute to arbitration and ruled that Tenant must make rent payments to Receiver. The court of appeals reversed. The Supreme Court affirmed, holding that the court of appeals properly concluded that Receiver was subject to the arbitration agreement in the lease. View "Wilmington Trust, Nat'l Ass'n v. 700 Hennepin Holdings, LLC" on Justia Law

by
The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's complaint alleging that Defendant violated the Minnesota Bond Allocation Act, Minn. Stat. 474A.01-.21, holding that Plaintiff alleged a violation of the Act sufficient to support her common-law and statutory claims.Plaintiff, who leased and lived in one of Defendant's rent-restricted housing units, brought this putative class action alleging that Defendant violated the Act, which imposes rent limits on residential rental projects financed with tax-exempt municipal bonds. The district court dismissed the complaint for failure to state a claim upon which relief can be granted, and the court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff stated a viable action, and therefore, the district court erred in dismissing her complaint. View "Thompson v. St. Anthony Leased Housing Associates II, LP" on Justia Law

by
In this landlord-tenant dispute, the Supreme Court reversed the decision of the court of appeals affirming the district court's denial of Tenant's claim for treble damages under Minn. Stat. 504B.231, holding that remand was required for the court of appeals to address one remaining issue left unaddressed by its decision.Landlord resorted to self-help measures to remove Tenant from a residential premises. Tenant filed a petition for possession of residential rental property following unlawful removal under Minn. Stat. 504B.375 (the lockout petition) and sought treble damages for ouster under section 504B.231. The district court dismissed the lockout petition, concluding that Tenant was not a "residential tenant" and that Landlord did not act in bad faith. The court of appeals affirmed. The Supreme Court reversed, holding (1) to recover treble damages under section 504B.231, tenants must established that their landlord removed them from a residential premises unlawfully and in bad faith; and (2) remand was required for the court of appeals to determined whether Tenant was a tenant under section 504B.231(a). View "Reimringer v. Anderson" on Justia Law

by
The Supreme Court held in this eviction action that, under the circumstances of this case, the retaliation defense was not available under Minn. Stat. 504B.441 but that the common law should recognize a defense when a landlord retaliates against a tenant for making a good-faith complaint to the landlord of a material violation of a local or state law, residential covenants, or the lease.By special verdict, a jury found that Tenant materially violated the terms of the lease but that Landlord retaliated against Tenant as a penalty for complaining about the condition of the leased premises. The district court entered judgment for possession of the rental unit in favor of Tenant apparently based on the retaliation defense under Minn. Stat. 504B.285, subd. 2, and Minn. Stat. 504B.441. The court of appeals reversed, concluding that the retaliation defense was unavailable to Tenant under either statutory provision. The Supreme Court affirmed in part and reversed in part, holding (1) Tenant could not assert a statutory defense; but (2) the language of the verdict was adequate to satisfy the requirements of the common-law retaliation defense that the Court recognized today. View "Central Housing Associates, LP v. Olson" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming the decision of the district court finding for Tenant in the underlying eviction proceedings brought by Landlord and concluding that Landlord had breached the covenants of habitability, holding that a tenant asserting a common-law habitability defense in an eviction proceeding is not required to follow the procedures for an action under the rent-escrow statute, Minn. Stat. 504B.385.In response to Landlord’s action, Tenant raised the common-law habitability defense. The district court agreed with Tenant and ordered retroactive and prospective rent abatement until Landlord’s habitability violations were fixed. On appeal, Landlord argued that a tenant must follow the statutory procedures, including written notice, for a rent-escrow action under section 504B.385. The court of appeals held that Tenant was not required to do so. The Supreme Court affirmed, holding that written notice is not required before a tenant raises a common-law habitability defense to an eviction proceeding. View "Ellis v. Doe" on Justia Law

by
Appellant agreed with Respondent to rent an apartment located in Hennepin County. Respondent received the first month’s rent and security deposit but refused to deliver physical possession of the premises to Appellant. Appellant brought an unlawful exclusion petition under Minn. Stat. 504B.375 - the unlawful exclusion statute - to enforce her agreement with Respondent. The housing referee recommended granting Respondent’s motion to dismiss on the grounds that Appellant did not qualify as a “residential tenant” under the statute because she was not physically “occupying” the residential premises. The district court adopted the referee’s decision. The court of appeals affirmed. The Supreme Court reversed, holding (1) a tenant who holds the present legal right to occupy residential rental property pursuant to a lease or contract satisfies the definition of “residential tenant” under Minn. Stat. 504B.001, and (2) therefore, upon the effective date of a lease agreement, a tenant has the right to bring an unlawful removal or exclusion petition under Minn. Stat. 504B.375(1). View "Cocchiarella v. Driggs" on Justia Law

by
The apartment building in which Tenants lived was damaged by a fire. For purposes of this appeal, the parties agreed that the fire was caused by Tenants’ negligence. Landlord’s insurer paid for the repairs to the building and then brought this subrogation action against Tenants in the name of Landlord to recover the money it paid to repair the damage caused by the fire. The district court granted summary judgment in favor of Tenants, determining that the parties did not reasonably expect that Tenants would be liable for the damage they caused. The court of appeals reversed, concluding that the lease agreement clearly reflected the parties’ intention that Tenants would reimburse Landlord for any damage caused by their negligence. The Supreme Court affirmed in part and reversed in part, holding (1) under the circumstances of this case, it is reasonable that Tenants should be liable for negligence they caused to the leased premises; but (2) the parties would not reasonably have expected that Tenants would be liable for damage to other property belonging to Landlord. Remanded. View "Melrose Gates, LLC v. Moua" on Justia Law

by
The apartment building in which Tenants lived was damaged by a fire. For purposes of this appeal, the parties agreed that the fire was caused by Tenants’ negligence. Landlord’s insurer paid for the repairs to the building and then brought this subrogation action against Tenants in the name of Landlord to recover the money it paid to repair the damage caused by the fire. The district court granted summary judgment in favor of Tenants, determining that the parties did not reasonably expect that Tenants would be liable for the damage they caused. The court of appeals reversed, concluding that the lease agreement clearly reflected the parties’ intention that Tenants would reimburse Landlord for any damage caused by their negligence. The Supreme Court affirmed in part and reversed in part, holding (1) under the circumstances of this case, it is reasonable that Tenants should be liable for negligence they caused to the leased premises; but (2) the parties would not reasonably have expected that Tenants would be liable for damage to other property belonging to Landlord. Remanded. View "Melrose Gates, LLC v. Moua" on Justia Law