Justia Landlord - Tenant Opinion Summaries

In the case before the Supreme Court of the State of Idaho, the plaintiffs, Dallen and Rachel Worthington, filed an expedited unlawful detainer action against the defendant, Carlene Crazy Thunder, for failure to pay rent. Crazy Thunder requested a jury trial, which was denied by the magistrate court. Following a bench trial, the magistrate court ruled that Crazy Thunder had unlawfully detained the Worthingtons’ property and ordered her to vacate the residence. Crazy Thunder appealed to the district court, arguing she had a right to a jury trial under Idaho’s constitution and Idaho Code section 6313. The district court agreed, concluding that section 6-311A conflicted with section 6-313, and that section 6-311A violated Article I, section 7 of the Idaho Constitution. The Worthingtons then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho held that Idaho Code section 6-311A does not violate the Idaho Constitution. The court reasoned that an action for unlawful detainer is an equitable claim, and under Article I, section 7 of the Idaho Constitution, the right to trial by jury only exists for legal claims, not equitable ones. However, the court also ruled that Crazy Thunder was entitled to a jury trial on her legal claims. The court held that in wrongful detainer cases like this one, when issues of fact are presented by the pleadings, those issues must be tried by a jury, unless such a jury is waived. As such, the Supreme Court of Idaho affirmed the district court’s decision, though on different grounds. The court further ruled that Crazy Thunder, as the prevailing party on appeal, was entitled to costs, but neither party was entitled to attorney fees. View "Worthington v. Crazy Thunder" on Justia Law

In the case before the Supreme Court of Ohio, the issue concerned whether a landlord or landlord's agent can prohibit a person from entering leased premises, even if that person has received permission from a tenant. The case arose when Antonio Randolph was banned from an apartment complex by the property manager and was then later arrested and charged with criminal trespass after he was discovered in his uncle's apartment at the complex, which his uncle had invited him to. The trial court found Randolph guilty of criminal trespass. The Sixth District Court of Appeals reversed the trial court's judgment, holding that the city had to prove that Randolph had entered the premises without privilege, and that his uncle's invitation to the apartment contradicted this.Upon review, the Supreme Court of Ohio agreed with the Sixth District's decision. The court held that a landlord or landlord's agent generally may not exclude a person from rented premises such that the excluded person is considered a trespasser when on the premises even if the person received permission to enter the premises from a tenant of the property. The court noted that Ohio law provides that a landlord cedes his or her possessory interests in leased property to the tenant and therefore may not prohibit the tenant from inviting guests onto the property.However, the court also highlighted that a landlord can maintain control over access to a property if the landlord so desires, provided that this authority is reserved in the lease agreement. In the absence of such a provision in the lease agreement, a tenant may invite onto the property a person whom the landlord has sought to ban from the premises. The judgment of the Sixth District Court of Appeals was affirmed. View "State v. Randolph" on Justia Law

In Washington, a couple, the Lewises, moved into a rental property owned by another couple, the Ridgways. After the Lewises moved out, a dispute arose over the return of their security deposit. The Ridgways claimed the Lewises caused damage to the property and deducted repair costs from the deposit. The Lewises disputed these charges, and the case was sent to arbitration. During arbitration, the Lewises were awarded the full amount of their security deposit, but the Ridgways were given attorney fees under the small claims statute. The Lewises attempted to appeal the arbitration award and a pre-arbitration order granting partial summary judgment to the Ridgways. However, the Lewises did not personally sign their request for a trial de novo, a requirement under court rules and the arbitration statute.The Washington Supreme Court held that the Lewises' request for a trial de novo was ineffective because they did not personally sign the request, as required by the court rule and the arbitration statute. The court also held that, absent a valid request for a trial de novo, the Lewises could not appeal the pre-arbitration order granting partial summary judgment to the Ridgways. The court further stated that the question of who should be considered the prevailing party for the purpose of any attorney fee award needed further consideration, and remanded the case back to the lower court for determination of attorney fees. View "Crossroads Mgmt., LLC v. Ridgway" on Justia Law

The case pertains to an appeal by plaintiff William J. Papp, III, against the decision of a single justice of the Supreme Judicial Court denying his request for declaratory relief, a stay of eviction, and relief in the nature of certiorari in relation to a housing dispute. The dispute centered around Papp's objection to the transfer of his case against the defendant landlord from the Superior Court to the Central Division of the Housing Court Department, which he alleged was in violation of G. L. c. 185C, § 20 and deprived him of due process.The Supreme Judicial Court upheld the single justice's decision, affirming that Papp had failed to adequately demonstrate that other remedies were not available to him. The court noted that Papp could have sought interlocutory review of the transfer order from a single justice of the Appeals Court, as per G. L. c. 231, § 118, first par. Additionally, he could have appealed the transfer order as part of an appeal from the final judgment of the Housing Court. Therefore, since Papp could not establish the absence or inadequacy of other remedies, the single justice had not erred or abused her discretion in denying Papp's claims for relief. View "Papp v. Westborough Gardens LLC" on Justia Law

The case involves an appeal by a landlord, Carline Vilbon, against her tenant, Judy Vargas, in an eviction action. The landlord had sought possession of the rental property and reasonable use and occupancy damages from the termination date through the date Vargas vacated the property. The Superior Court granted Vilbon possession but dismissed her claim for use and occupancy as well as for money damages. Vilbon appealed the Superior Court's decision to the Supreme Court of Rhode Island.The Supreme Court of Rhode Island affirmed the order of the Superior Court. The court found that without a transcript of the proceedings, it could not determine whether the trial justice had abused his discretion in either dismissing Vilbon’s claims or denying her motion to vacate the consent order. The court held that the burden of furnishing the court with the necessary records to enable it to pass on the alleged error lay with the party alleging the error. As such, the court concluded that Vilbon's failure to provide an adequate transcript was fatal to her claims. View "Vilbon v. Vargas" on Justia Law

In a case before the Supreme Judicial Court, the Attorney General of Massachusetts initiated a civil action in the Superior Court alleging housing discrimination by the defendant, Mark Davidson, on behalf of two complainants. The defendant transferred the case to the Housing Court, after which the Attorney General unsuccessfully sought to have the matter transferred back to the Superior Court, arguing that the Housing Court lacked jurisdiction over a discrimination claim in this procedural posture. The complainants had initially filed an administrative complaint with the Massachusetts Commission Against Discrimination, alleging that the defendant had terminated their lease upon learning that one of the complainants was pregnant, allegedly to avoid having to comply with the lead containment or abatement statute. The defendant chose to have the matter heard in court rather than by the commission.The Supreme Judicial Court held that, based on the language of G. L. c. 151B, § 5, the Superior Court is the proper court for actions such as this one, and that the Housing Court lacks jurisdiction. The court reasoned that the language of § 5 unambiguously indicates that the Superior Court is the proper court for such actions. The court also noted that the Legislature's use of the word "shall" suggests a command to commence the action in the Superior Court, and not elsewhere, and the phrase "commence and maintain" is a clear directive that such actions brought by the Attorney General, once initiated, are to remain in the Superior Court. Therefore, the order of the single justice of the Appeals Court was affirmed, and the stay of any proceedings in the Superior Court was vacated. The case must be returned to the Superior Court. View "Commonwealth v. Davidson" on Justia Law

The Supreme Court reversed judgments issued by the district court in these consolidated appeals concerning the interpretation of the Montana Residential Mobile Home Lot Rental Act as it related to mobile home owners who had been evicted from their lots, holding that the Act does not allow for a no-cause termination of a periodic tenancy.David and Doreen Lockhart appealed the order issued by the district court upholding the order for possession issued by the justice court and ordering them to vacate and remove all personal property from a mobile home lot owned by Westview Mobile Home Park, LLC. Hydi Cunningham appealed the district court orders following the justice court's judgment and order for possession of property and writ of issuance ordering Cunningham to vacate the mobile home lot she had been renting from Greener Montana Property Management, LLC. The Supreme Court reversed in both causes, holding (1) the Act does not allow a lot-only landlord to terminate a homeowner tenant's month-to-month lease without cause; and (2) therefore, the no-cause terminations of both leases in this case were illegal and invalid. View "Greener Montana Property Management LLC v. Cunningham" on Justia Law

In 1994, Duncan moved into a rent-controlled unit in San Francisco. He was living there with his family when, in 2014, the landlords purchased the building and took away property-related benefits, ignored or delayed maintenance, were uncommunicative and uncooperative, and became increasingly hostile. While living in their unit, the tenants sued the landlords, alleging nuisance, breach of contract, negligence, harassment under San Francisco’s Residential Rent Stabilization and Arbitration Ordinance, and unfair business practices (Bus. & Prof. Code 17200). Unlawful detainer actions were then filed against the tenants, who asserted affirmative defenses of retaliation and violation of the Rent Ordinance but later vacated the premises The landlords then unsuccessfully argued that because the tenants did not file a cross-complaint in the unlawful detainer actions, they were barred from pursuing their already-pending separate action. In 2016, the tenants added an allegation of unlawful owner move-in eviction. The jurors found the landlords liable under the Rent Ordinance and awarded $2.7 million. The court of appeal affirmed in 2021.The landlords nonetheless filed motions to vacate, claiming that the trial court had lacked subject matter jurisdiction over the tenants’ claims after they surrendered possession of their unit. The court of appeal affirmed the rejection of that claim. The only legal claim the tenants abandoned by moving out was current possession. The tenants’ other claims were not waived and were not required to be litigated in the unlawful detainer actions. View "Duncan v. Kihagi" on Justia Law

Between 2015 and 2019, BitterSweet Ranch and its managers (“BitterSweet”) leased three parcels of farmland from Frank Sullivan and two of his business entities, The Green Desert, LLC, and The Sullivan Limited Partnership (collectively, “Sullivan”). The parties signed three identical five-year leases (“the Leases”) involving three separate parcels of real property, each owned by one of the three Sullivan parties. The Leases specified that Sullivan was to be responsible for payment of the property taxes, but that those parties were to be reimbursed by BitterSweet, and that BitterSweet was to be responsible for bi-annual rent payments, utilities, and water assessments. For a variety of reasons, the parties purportedly orally agreed to modify the Leases to offset amounts owed to each other throughout the terms of the Leases. Shortly before the Leases were set to expire at the end of their five-year terms, Sullivan claimed that BitterSweet was in breach of the Leases for its alleged failure to make timely rent payments, to pay all property taxes, and to pay the water assessments pursuant to the terms of the Leases. Sullivan then filed three lawsuits (one for each of the Leases and in the names of each of the three parties) in district court. The district court ordered the cases consolidated and then granted summary judgment in favor of BitterSweet, concluding that a genuine issue of material fact had not been created as to whether BitterSweet had breached the Leases. Sullivan appealed the adverse order. Finding no reversible error, the Idaho Supreme Court affirmed. View "Sullivan v. BitterSweet Ranch, LLC" on Justia Law

This consolidated appeal arose from a dispute regarding a purchase option within a lease agreement. Bronco Elite Arts & Athletics, LLC, and its manager and registered agent, Brandon Paine (collectively “Bronco Elite”), operated a gymnastics facility in Garden City, Idaho. The gymnastics facility was located on property that Bronco Elite leased from 106 Garden City, LLC (“106 Garden City”), and Tricon Properties, LLC (“Tricon”). The lease agreement provided Bronco Elite the option to purchase the Property five years into the initial ten-year lease term. However, when Bronco Elite attempted to exercise its option, 106 Garden City and Tricon refused to honor the option. Bronco Elite sued 106 Garden City and Tricon, seeking specific performance. 106 Garden City and Tricon argued that Bronco Elite was precluded from exercising its purchase option because Bronco Elite had breached the lease agreement by consistently failing to pay rent on time and the lease terms only permitted Bronco Elite to exercise the purchase option if it was not in breach. The district court granted summary judgment in favor of Bronco Elite and ordered 106 Garden City and Tricon to convey the Property to Bronco Elite. The specific performance ordered by the district court was stayed pending appeal. After review, the Idaho Supreme Court concluded the district court did not err in granting summary judgment to Bronco Elite, however, the Court found the trial court erred in setting the purchase price of the Property in the way that it did. The case was remanded for further proceedings. View "Bronco Elite Arts & Athletics, LLC v. 106 Garden City, LLC" on Justia Law