Justia Landlord - Tenant Opinion Summaries

A commercial tenant in Minneapolis, Seven Acquisition LLC, operated its business in a building owned by 700 Hennepin Holdings LLC and subject to a mortgage held by a bank. After the landlord failed to repair a leaking roof, Seven withheld rent, leading to an eviction action. Seven prevailed in arbitration against the landlord and was awarded damages. The landlord then defaulted on the mortgage, prompting the bank to initiate foreclosure proceedings and request the appointment of Gregg Williams as receiver. Despite claims of independence, Seven alleged Williams had significant prior business with the bank’s agent. As receiver, Williams controlled the property, but Seven alleged he refused necessary repairs and acted to evict them for the bank’s benefit.In response, Seven sought to have Williams removed as receiver, arguing he was not independent and failed in his duties, but the Hennepin County District Court denied this motion as untimely and unsupported by good cause. Seven then filed a separate lawsuit against Williams, asserting negligence and breach of fiduciary duty. The district court dismissed the negligence claim based on quasi-judicial immunity, but allowed the fiduciary duty claim to proceed, finding factual questions regarding Williams’s independence and actions.Williams appealed, and the Minnesota Court of Appeals reversed, holding that quasi-judicial immunity protected Williams from suit for all actions taken within the scope of his receivership, regardless of motive or alleged conspiracy with the bank. The Supreme Court of Minnesota affirmed this decision. The court held that quasi-judicial immunity shields a court-appointed receiver from lawsuits for actions taken within the scope of the appointment, even if the receiver is alleged to have acted at the direction of a party or with improper motive. The complaint’s allegations were found insufficient to defeat this immunity. The decision of the court of appeals was affirmed. View "Seven Acquisition LLC vs. Williams" on Justia Law

The case arose when a property owner initiated an eviction action against a tenant. The parties resolved the matter through a court-approved settlement, under which the tenant agreed to vacate the apartment by a specified date. The tenant complied with the settlement terms. Several months later, the tenant moved for expungement of the eviction record, relying on a recently amended Minnesota statute providing that courts must expunge eviction files if the case is settled and the defendant fulfills the terms of the settlement.A housing court referee recommended expungement pursuant to that statute, and the district court signed the expungement order. The property owner, Sela Investments, appealed to the Minnesota Court of Appeals, arguing that the statutory expungement provision was unconstitutional. The Court of Appeals agreed, holding that the statute was a facial violation of the separation of powers because it infringed on the judiciary’s inherent authority to manage its own records. The appellate court reversed the expungement and remanded for the district court to apply a discretionary balancing test instead.On review, the Supreme Court of Minnesota first considered whether Sela Investments had standing to challenge the constitutionality of the statute. The court held that to have standing for a constitutional challenge, a party must show the statute has disadvantaged or is about to disadvantage its legal interest or right. The Supreme Court found that Sela Investments had not been harmed by the expungement statute, as it retained its own knowledge of the tenant and did not lose any legal right or interest.Because Sela Investments lacked standing, the Supreme Court held that neither it nor the Court of Appeals had jurisdiction to adjudicate the constitutional claim. The Supreme Court therefore vacated the decision of the Court of Appeals. View "Sela Investments, Ltd LLP vs. J.H." on Justia Law

A tenant entered into a lease for an apartment in Minneapolis that was subsidized under the Section 8 project-based voucher program, with the local public housing authority paying most or all of the rent directly to the landlord. After the tenant fell behind on utility payments, her electricity was disconnected, and she and her boyfriend broke into the building’s utility closet to restore power, inadvertently affecting other units. The landlord learned of this breach but continued to accept three months of rental payments from the public housing authority on the tenant’s behalf. Later, the landlord filed an eviction action based on the tenant’s breach of the lease.The Hennepin County District Court dismissed the tenant’s counterclaim regarding the utility shutoff and, following the Minnesota Court of Appeals’ decision in Westminster Corp. v. Anderson, held that the common law doctrine of waiver by acceptance of rent did not apply to rental payments made by a public housing agency. The district court found the tenant had materially breached the lease and did not address her retaliation defense. The Minnesota Court of Appeals affirmed the district court’s rulings on the waiver and breach issues but remanded for consideration of the retaliation defense.The Minnesota Supreme Court reviewed only the waiver issue. It overruled Westminster, holding that the common law rule—whereby a landlord who accepts rent with knowledge of a tenant’s breach waives the right to evict for that breach—applies equally to private and publicly subsidized tenancies. The court clarified that whether a landlord has accepted rent for purposes of this doctrine is a factual question, to be determined by the totality of the circumstances, including the landlord’s conduct after payment. The Supreme Court reversed the court of appeals and remanded for further proceedings. View "Hook & Ladder Apartments, L.P. v. Nalewaja" on Justia Law

The case revolves around Lisa Stone, a tenant who signed a lease agreement that required her to provide maintenance services for which she alleges she was not compensated, in violation of Minnesota law. She initiated a class-action lawsuit against Invitation Homes, Inc., the parent company of her landlord, and THR Property Management, L.P., the manager of the leased property. Stone later amended her complaint to include various subsidiaries of Invitation Homes as defendants. Some of these subsidiaries argued that Stone lacked standing to sue them as she had not alleged that they had caused any injuries.The district court denied the subsidiaries' motion to dismiss. The subsidiaries appealed this decision to the court of appeals, which reversed the district court's decision and dismissed Stone's claims against the subsidiaries. The court of appeals reasoned that Stone lacked standing to bring her claims under the theory for standing found by the district court, and the juridical-link doctrine was improperly raised by Stone for the first time on appeal and did not apply in this case.Stone appealed to the Supreme Court of Minnesota, arguing that she has standing against the subsidiaries under the juridical-link doctrine. This doctrine posits that in a class action in which a named plaintiff has not alleged an injury caused by all defendants, a class may be certified when all defendants are linked by a conspiracy or concerted scheme that harmed the class. However, the Supreme Court affirmed the decision of the court of appeals, stating that Stone had forfeited the ability to have the merits of standing under the juridical-link doctrine determined on appeal as she failed to assert standing based on the juridical-link doctrine in the district court. View "Stone, vs. Invitation Homes, Inc." on Justia Law

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

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

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

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

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

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