Justia Landlord - Tenant Opinion Summaries

Articles Posted in Iowa Supreme Court
After Tenants moved out of an apartment, Landlord deducted $904 fomr the rental deposit for an automatic carpet-cleaning charge, replacement of an interior door, and monthly penalties for failure to pay for the door. Tenant filed a small claims action alleging that Landlord unreasonably failed to return the rental deposit and willfully used a rental agreement with known prohibited provisions. A magistrate determined that Landlord violated the Iowa Uniform Residential Landlord and Tenant Act (IURLTA) by requiring Tenants to pay for the interior door repair and for the cost of carpet cleaning. The magistrate concluded that Tenant was entitled to punitive damages for bad-faith retention of the rental deposit and an award of two months’ rent for willfully using provisions in its rental agreement that violated the IURLTA. The magistrate awarded Tenant an additional two months’ rent and attorneys’ fees. The district court affirmed. The Supreme Court affirmed in all respects except on the issue of a knowing use of provisions violating the IURLTA and a bad-faith retention of the rental deposit, holding (1) the record does not contain sufficient evidence to support a knowing violation of the IURLTA, and (2) there was insufficient fact-finding on the issue of bad-faith retention of the rental deposit. Remanded. View "Caruso v. Apartments Downtown, Inc." on Justia Law