Justia Landlord - Tenant Opinion Summaries

A tenant and her young son resided in a rental property owned by a landlord. The tenant failed to pay rent for August 2024, prompting the landlord to file an eviction action in the Rhode Island District Court for nonpayment. The District Court held a hearing, after which it awarded possession to the landlord and entered a damages judgment against the tenant. The tenant appealed to the Superior Court, raising an affirmative defense and counterclaim based on alleged uninhabitability of the premises due to plumbing problems and a sewage fly infestation.While the appeal was pending in the Superior Court, the landlord moved to dismiss the appeal, arguing that the tenant’s failure to pay a prorated portion of September rent (covering the period after judgment in District Court but before the next rent due date) mandated dismissal under the Residential Landlord and Tenant Act. The tenant conceded nonpayment of that portion but argued the statute only required payment of full rent due after the appeal was taken, which she had paid in October. The Superior Court agreed with the landlord and dismissed the appeal.The Supreme Court of Rhode Island granted certiorari and reviewed the statutory interpretation. The Court held that under the plain language of the relevant statutes, a tenant appealing an eviction judgment is obligated to pay rent only on the next scheduled due date after the appeal is filed, not a prorated portion for days between judgment and the next rent due date. The Court further held that after the tenant vacated the apartment, the case ceased to be an action for recovery of real property, and the statutory rent-payment requirement no longer applied. The Supreme Court quashed the Superior Court’s order of dismissal and remanded the case for further proceedings on damages. View "Pioneer Investments, LLC v. McKiernan" on Justia Law

A tenant operating a restaurant under a commercial lease failed to provide written notice of its intent to renew the lease by the contractually required deadline. The lease allowed renewal for additional terms if the tenant gave written notice at least ninety days before the current term expired. In 2022, the tenant closed for renovations without the landlord’s written consent and remained closed for several months, citing purported structural issues. The landlord, finding this closure and unauthorized work to be defaults under the lease, initiated termination proceedings and provided notice of lease termination. Despite several communications and actions by both parties—including the landlord’s filing and dismissal of eviction actions—the tenant did not provide timely written notice of renewal.A magistrate in Johnson County entered judgment and an order of possession in favor of the landlord. The tenant appealed to the Iowa District Court for Johnson County, which affirmed the magistrate’s ruling. The tenant then sought further review, and the case was transferred to the Iowa Court of Appeals, which also affirmed the lower courts’ decisions.On discretionary review, the Iowa Supreme Court considered whether the lease had been orally modified to permit renewal without written notice, whether the landlord’s actions had revoked or excused the renewal option, and whether the landlord’s conduct constituted a repudiation of the lease. The court held that the lease’s written notice requirement for renewal was controlling and found insufficient evidence of a modification to permit oral renewal. The court also concluded that the landlord’s termination and eviction actions, taken in good faith in response to the tenant’s breach, did not revoke the renewal option or constitute repudiation. The Iowa Supreme Court affirmed the decisions of the lower courts. View "MidWestOne Bank v. Short's Burger & Shine, LLC" on Justia Law

A dispute arose between a commercial landlord and tenant after government emergency orders during the COVID-19 pandemic required non-essential businesses in New York City to close. The tenant, operating a retail clothing store in Manhattan, stopped paying rent, arguing that the lease excused rent payments when government actions prevented it from operating its business. The landlord disagreed, terminated the lease for nonpayment, and sought damages for breach of contract. The tenant vacated the premises and counterclaimed, alleging the landlord wrongfully terminated the lease and wrongfully kept two payments made after termination.The United States District Court for the Southern District of New York granted summary judgment in favor of the landlord, finding that the government’s orders did not constitute a “taking” under the lease because the tenant was not fully deprived of the use or occupancy of the premises. The district court also rejected the tenant’s counterclaims for breach of contract and unjust enrichment, holding that the notice-and-cure provision applied and that the unjust enrichment claim was duplicative. The court awarded damages to the landlord, though the landlord cross-appealed, asserting the award was insufficient.The United States Court of Appeals for the Second Circuit reviewed the case. It held that the district court misinterpreted the lease’s takings provision, which excused the tenant from paying rent when it was unable to operate its business due to government orders. The appellate court reversed the summary judgment for the landlord on its breach of contract claim and concluded the tenant was entitled to summary judgment on both its own breach of contract counterclaim and its claim that the landlord improperly terminated the lease. The court further vacated the judgment on the unjust enrichment counterclaim and remanded for further proceedings. The landlord’s cross-appeal on damages was dismissed as moot. View "Delshah 60 Ninth, LLC v. Free People of PA LLC" on Justia Law

The case involves a tenant, Ms. Craig, who uses a wheelchair and lived in an apartment managed and owned by the appellants. Her rent was paid through a D.C. housing voucher, but she was responsible for utilities and parking. The appellants sought to evict her after alleging she failed to pay these additional charges. At the eviction hearing in the Landlord and Tenant Branch (L&T) of the Superior Court, the appellants claimed to have served Ms. Craig through her brother, but the affidavit described her brother instead of Ms. Craig. Despite this, the L&T court found service sufficient and entered a default judgment against her, resulting in her eviction.After her eviction, Ms. Craig filed motions in the L&T court to vacate the default judgment and for emergency relief, but did not receive prompt action. She then filed a separate complaint and sought a preliminary injunction in the Civil Division of the Superior Court, arguing improper service and irreparable harm. The Civil Division granted a preliminary injunction restoring her to the apartment, pending the L&T court’s decision on her motion to vacate. Subsequently, the L&T court vacated the default judgment and dismissed the eviction action, and Ms. Craig was returned to her apartment.The District of Columbia Court of Appeals addressed whether the Civil Division could grant temporary injunctive relief from the L&T court’s default judgment while a motion to vacate was pending. The court held that, under limited circumstances where a litigant first seeks relief in the issuing court, a collateral court may grant temporary relief to prevent irreparable harm while awaiting the issuing court’s decision. The court affirmed the Civil Division’s preliminary injunction, holding that such temporary relief does not contravene Rule 60 or res judicata when properly limited. View "Bozzuto Management Co. v. Craig" on Justia Law

A commercial tenant operating a beer and wine store in Maryland entered into a five-year lease requiring it to pay base rent as well as additional charges—including real estate taxes, water and sewer bills, late fees, HVAC replacement costs, and attorneys’ fees—that the lease defined as “Additional Rent.” The lease contained a clause by which the tenant waived its statutory right of redemption, meaning it could not prevent eviction by paying the overdue amounts after judgment. After the tenant fell behind on these additional charges but remained current on base rent, the landlord filed a summary ejectment action to repossess the premises.The District Court for Frederick County found the tenant liable for most of the claimed additional charges and, relying on the lease’s waiver clause, awarded the landlord possession with no right of redemption. On appeal, the Circuit Court for Frederick County vacated that judgment, holding that some attorneys’ fees were improperly included as unpaid rent and that the tenant lacked adequate notice of certain charges, making the redemption waiver unenforceable.The Supreme Court of Maryland reviewed the case. It held that in nonresidential leases, a waiver of the statutory right of redemption does not violate Maryland public policy and is enforceable unless a traditional contract defense applies. The court also clarified that the statutory pre-suit notice requirement in Real Property Article § 8-401(c)(1) applies only to residential tenancies and not to commercial ones. However, it held that a landlord may recover possession only for rent that is due and unpaid under the lease, and summary ejectment cannot be based on charges of which the tenant had no prior notice before suit was filed.The Supreme Court of Maryland vacated the judgment of the circuit court and remanded for recalculation of the rent due, instructing that only charges for which the tenant had received prior notice and the contractual time to pay could support possession. View "Kapneck 14-16 v. Breezy's Speakeasy" on Justia Law

The plaintiffs, including a state commission and two tenants, alleged that the owner and management of an apartment complex discriminated against them by refusing to allow two emotional support dogs, despite a general no-pet policy. The tenants had previously lived at another complex that allowed both dogs as emotional support animals. Upon applying to the new complex, they provided documentation for the accommodation, but the defendants only approved one dog and requested further justification for the second. After the tenants objected to the additional requests, the defendants cancelled their lease and refunded their payments. The tenants subsequently found other housing.The Superior Court found for the plaintiffs, holding that the defendants had discriminated against the tenants by constructively denying their request for a reasonable accommodation, in violation of Connecticut's fair housing law. The court determined that the tenants had established the required elements for a failure-to-accommodate claim, specifically finding that one plaintiff was “regarded as” having a mental disability by the defendants.The defendants appealed to the Connecticut Appellate Court, which reversed the trial court’s judgment. The Appellate Court found that, although the plaintiff was regarded as having a disability, there was insufficient proof that the second dog was necessary for equal use and enjoyment of the dwelling. The Appellate Court also interpreted the trial court’s findings as implicitly determining that the plaintiff had a "record of" a disability.On further appeal, the Connecticut Supreme Court affirmed the reversal of the trial court’s judgment but vacated portions of the Appellate Court’s decision that addressed whether there was a “record of” disability and the legal standard for “necessity” of an accommodation. The Connecticut Supreme Court held that, because the trial court only found the plaintiff was "regarded as" having a disability, she was not entitled to a reasonable accommodation. View "Commission on Human Rights & Opportunities ex rel. Pizzoferrato v. Mansions, LLC" on Justia Law

A California company repurposed decommissioned military bunkers in South Dakota as survival shelters, offering them for sale or long-term lease. In 2020, an individual entered into a 99-year lease with the company for one of these bunkers, paying $35,000 upfront. The lease agreement incorporated a set of community rules, which the company reserved the right to modify with 30 days’ written notice. In 2021, the company amended the rules to expressly prohibit the brandishing of firearms except in designated areas. In 2023, the lessee was alleged to have brandished a firearm during an altercation, prompting the company to issue notices to vacate and, ultimately, to file a forcible entry and detainer action when the lessee secured the bunker but refused to return possession.The Circuit Court of the Seventh Judicial Circuit in Fall River County granted summary judgment in favor of the lessee. The court reasoned that the lease was illusory because the company could unilaterally modify the rules at any time, leaving the lessee with no recourse. The court concluded that this rendered the entire lease void and unenforceable, thereby preventing the company from evicting the lessee under the lease.The Supreme Court of the State of South Dakota reversed the circuit court’s summary judgment order. The Supreme Court held that the lease agreement was supported by valid consideration and was not illusory merely because the company retained the right to modify community rules, as such modifications were constrained by requirements of reasonableness and good faith. The Court ruled that the ability to modify rules, when exercised subject to notice and implied duties of good faith and fair dealing, does not make the underlying contract unenforceable. The case was remanded for further proceedings. View "Vivos Xpoint v. Sindorf" on Justia Law

A nonprofit organization representing manufactured home community owners and a mobilehome park owner challenged the City of Santa Rosa’s enforcement of California Penal Code section 396 during a multi-year wildfire state of emergency. Section 396 prohibits increasing the rental price of mobilehome spaces by more than 10 percent during a declared emergency. The plaintiffs argued that, under Santa Rosa’s rent control ordinance, park owners should be able to impose annual increases according to the ordinance’s Consumer Price Index (CPI) formula, even if those increases cumulatively exceeded the 10 percent cap in section 396. Alternatively, they sought to “reset” post-emergency rents as if the suppressed CPI increases during the emergency had been implemented.The Sonoma County Superior Court denied the plaintiffs’ motions for summary judgment and granted the City’s, finding that section 396’s 10 percent cap was fixed at the rent authorized when the emergency began and that owners could not recoup lost increases after the emergency ended. The court reasoned that allowing such recoupment would defeat the statute’s purpose to protect consumers from excessive rent hikes during emergencies. The court entered judgment for the City after the plaintiffs’ third cause of action was dismissed by stipulation.On appeal, the California Court of Appeal, First Appellate District, Division Four, reviewed the case de novo. The appellate court held that section 396’s cap applies to the rent authorized at the start of the emergency and lasts for its duration, regardless of local rent control provisions. The court further ruled that nothing in section 396 or the local ordinance entitles park owners to recoup suppressed rent increases once the emergency ends. The court affirmed the trial court’s judgment in favor of the City and awarded costs to the City. View "Western Manufactured Housing Cmty. Assn. v. City of Santa Rosa" on Justia Law

A tenant who lived in an apartment complex for twelve years experienced severe habitability problems, including lack of heat for seven years, no functioning toilet for at least a year, no refrigerator for two years, a collapsed ceiling, and frequent mice infestations. The tenant sued his landlord, requesting only monetary damages, and later alleged that the landlord attempted to force him out by cutting off his electricity. The landlord argued it had offered relocation assistance or money to persuade the tenant to move out so renovations could be completed.The Superior Court of the District of Columbia found that the landlord breached the implied warranty of habitability, as the record showed the apartment was uninhabitable and the landlord did not contest the poor conditions. However, the court reduced the damages award to $7,500, reasoning that the tenant failed to mitigate his damages by refusing to vacate the apartment when offered relocation. The court also ordered the tenant to vacate within seven days, though the propriety of this order was not challenged on appeal.On appeal, the District of Columbia Court of Appeals held that a tenant does not have a duty to mitigate damages by vacating a rental unit in response to a landlord’s request for renovation unless the landlord first complies with D.C. Code § 42-3505.01(f)(1). This statute requires landlords to follow a specific process involving notice and approval by the Rent Administrator before temporarily recovering possession for renovations. The appellate court found no evidence the landlord had complied with this process. It reversed the trial court’s reduced damages award and remanded for a recalculation, directing that the tenant must be awarded at least $22,788. View "Woodley v. Woodberry Village Apartment" on Justia Law

Two former tenants sued the owner and manager of a residential apartment complex, alleging that they were charged unlawful rental application fees and excessive lock change fees, in violation of the Massachusetts security deposit statute and consumer protection laws. They sought to represent a statewide class of similarly situated tenants. After contentious discovery, the Superior Court sanctioned the defendants, precluding them from contesting certain liability facts. The court granted summary judgment to the plaintiffs on the security deposit claims but denied summary judgment on the consumer protection claims. Before trial, the parties reached a proposed class action settlement that established a fund for class members, with unclaimed funds to be distributed partly to charities and partly returned to the defendants.The Superior Court, after scrutiny and required revisions, approved the settlement. The court capped the amount of unclaimed funds that could revert to the defendants and required that a portion go to designated charities. However, the Massachusetts IOLTA Committee, a nonparty potentially entitled to notice under Mass. R. Civ. P. 23(e)(3), was not notified prior to settlement approval. After final approval and claims processing, the committee received notice for the first time and objected to the final distribution of unclaimed funds, arguing that the lack of timely notice violated the rule and that final judgment should be set aside. The motion judge agreed there was a violation but declined to vacate the settlement, finding no prejudice.On direct appellate review, the Supreme Judicial Court of Massachusetts held that the IOLTA Committee had standing to appeal the denial of its procedural right to notice and an opportunity to be heard on the disposition of residual funds, but lacked standing to challenge the overall fairness or structure of the settlement. Assuming a violation of the rule occurred, the Court found no prejudice because the committee ultimately received the opportunity to be heard before judgment entered. The judgment was affirmed. View "Ortins v. Lincoln Property Company" on Justia Law