Justia Landlord - Tenant Opinion Summaries

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The Supreme Court of New Jersey delivered an opinion concerning an appeal by condominium owners who claimed they were discriminated against because of their need for an emotional support animal (ESA) that exceeded the weight limit set by the condominium association's pet policy. The owners argued that their ESA, a 63-pound dog, was necessary for one of the owners who had been diagnosed with several mental health conditions. The court considered whether the trial court correctly dismissed the disability discrimination claims under New Jersey's Law Against Discrimination (LAD) and how requests of this type should be evaluated under the LAD.The court held that individuals seeking an accommodation must show they have a disability under the LAD and demonstrate that the requested accommodation may be necessary to afford them an "equal opportunity to use and enjoy a dwelling." The housing provider then has the burden to prove that the requested accommodation is unreasonable. Both sides should engage in good-faith, interactive dialogue in this process. If the parties cannot resolve the request, courts may be called on to balance the need for, and benefits of, the requested accommodation against cost and administrative burdens it presents. With this framework, the court found that the owners' claims should not have been dismissed and remanded the matter. View "Players Place II Condominium Association, Inc. v. K.P. and B.F." on Justia Law

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The plaintiff, Lourenco DoCouto, appealed a decision by the Superior Court of Rhode Island that dismissed his case against defendants Blue Water Realty, LLC and Louis Bachetti. The dispute centered around a property DoCouto claimed he had an option to purchase. DoCouto argued that the Superior Court erred in applying the doctrine of res judicata, dismissing his complaint for failure to timely serve defendants, and in determining that the District Court had jurisdiction over his equitable claims in the eviction proceedings.The Supreme Court of Rhode Island affirmed the Superior Court's decision. The court found that the parties in the eviction proceedings were the same or in privity with the parties in the present case. It also determined that DoCouto’s counterclaim in the eviction proceedings had alleged the same facts and arose out of the same transactions as those set forth in the current complaints. Therefore, the doctrine of res judicata applied, barring DoCouto’s claims.Moreover, the court disagreed with DoCouto’s claim that the District Court lacked jurisdiction over his equitable claims. As the eviction action pertained to a lease agreement, the court held that the District Court had the requisite jurisdiction over DoCouto’s equitable claims according to the Rhode Island statute. Lastly, the court rejected DoCouto’s argument that the District Court lacked jurisdiction over his request for compensatory damages for services rendered because the amount in controversy exceeded the statutory limit relative to District Court jurisdiction. The statutory maximum set forth had no bearing on the District Court’s subject matter jurisdiction over landlord-tenant cases such as this one. View "DoCouto v. Blue Water Realty, LLC" on Justia Law

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In this case, tenants Matthew Raines and Melissa Clayton complained to their landlord, Tuyen Dinh, about the habitability of their rented unit, particularly due to issues with their utilities and the presence of unauthorized tenants in the building. The tenants withheld rent and requested reimbursement for additional utilities costs. When Dinh refused and subsequently evicted the tenants for nonpayment of rent, a dispute ensued. The Superior Court of the State of Alaska held a damages trial, finding largely in favor of the tenants.The Supreme Court of the State of Alaska affirmed the lower court's findings that Dinh failed to maintain the premises in a habitable condition and willfully diminished the tenants' essential services under the Uniform Residential Landlord and Tenant Act (URLTA). However, the Supreme Court reversed the lower court's conclusion that the tenants could recover for the landlord's failure to deliver possession of the property. The Supreme Court also affirmed some aspects of the lower court's award of damages, but reversed those awards that were not supported by the record.The court found that Dinh's violation of housing codes and his conditional use permit diminished the value of the tenants' leasehold by the $8,800 owed in past rent. The court also found that Dinh was responsible for additional costs incurred by the tenants due to the unauthorized use of their utilities by unauthorized tenants in the building. However, the court ruled that the tenants could not recover for Dinh's failure to deliver possession of the property, despite finding that Dinh did not deliver habitable premises at the commencement of the lease. View "Dinh v. Raines" on Justia Law

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This case involves a dispute between Melissa Sanchez, a tenant, and Chris and Jennifer Pickering, her landlords, over the terms of a lease agreement for a mobile home owned by the Pickerings. Sanchez believed the agreement was a lease-to-own contract, while the Pickerings asserted it was a lease with a purchase option contract. After the Pickerings initiated an eviction action due to Sanchez's alleged violations of the agreement, Sanchez caused extensive damage to the home.The Pickerings sued Sanchez for waste, claiming she caused $40,000 in damages and sought treble damages. Sanchez counterclaimed, alleging violation of the Idaho Consumer Protection Act (ICPA), breach of contract, unjust enrichment, and retaliatory eviction. The district court found Sanchez liable for damages to the residence and awarded treble damages. It also determined that there was no deception on the Pickerings' part to sustain Sanchez's ICPA claim, the agreement was unenforceable due to a lack of mutual understanding, and that the Pickerings were unjustly enriched by the $10,000 down payment and offset the Pickerings' damages award by this amount. The remaining claims were dismissed.On appeal, the Supreme Court of Idaho affirmed the district court's decision. The court found substantial and competent evidence supporting the district court's decision that the Pickerings did not engage in a deceptive act under the ICPA. The court also rejected Sanchez's contention that the district court's damages award should have been reduced to reflect an insurance payment received by the Pickerings as Sanchez failed to provide an adequate record for review. Finally, the court upheld the district court's unjust enrichment award, finding that Sanchez had not demonstrated an abuse of discretion. The Pickerings were awarded attorney fees for having to respond to the collateral source issue. View "Pickering v. Sanchez" on Justia Law

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In this case from the Supreme Court of the State of Colorado, petitioner Claire E. Miller and respondent Jesse A. Amos were involved in a dispute related to eviction proceedings. Miller was a tenant who lived in a home owned and occupied by Amos. Their arrangement was an oral tenancy agreement where Miller agreed to provide pet care and light housekeeping services instead of paying rent. After six months, Amos served Miller with a notice to quit, alleging breach of their oral agreement. Miller refused to move out, and Amos filed a forcible entry and detainer (FED) complaint seeking eviction. Miller contended that her eviction was due to her refusal to engage in sexual acts with Amos, which she stated was a form of sex discrimination and retaliation under the Colorado Fair Housing Act (CFHA).The county court ruled in favor of Amos, stating that a landlord can serve a notice to quit for “no reason or any reason,” dismissing the CFHA violation claim as an affirmative defense for eviction. The district court affirmed this decision.On appeal, the Supreme Court of the State of Colorado reversed the lower court's ruling. The court held that a tenant can assert a landlord’s alleged violation of the CFHA as an affirmative defense to an FED eviction. The court noted that the purpose of the CFHA is to prevent discriminatory practices, and therefore, a tenant must be able to use it as a shield against a discriminatory eviction. The court also emphasized that a tenant's right to due process must be preserved even in eviction proceedings, which are intended to be expedited. This decision allows tenants in Colorado to assert discrimination or retaliation under the CFHA as a defense in eviction cases. View "Miller v. Amos" on Justia Law

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A plaintiff, Robert Trebelhorn, suffered a serious knee injury at his apartment complex when a section of an elevated walkway collapsed due to deterioration. The defendants, Prime Wimbledon SPE, LLC, and Prime Administration, LLC, who owned and managed the apartment complex, were aware of the deteriorated condition of the walkway but chose not to repair it. Trebelhorn sued the defendants for negligence and violation of Oregon's Residential Landlord-Tenant Act and won. The jury awarded him just under $300,000 in damages and also imposed punitive damages of $10 million against each defendant. On post-verdict review, the trial court concluded that although the evidence supported some amount of punitive damages, the amount of $10 million would violate the defendants' due process rights. The trial court reduced the punitive damages to just under $2.7 million against each defendant. On cross-appeals, the Court of Appeals agreed with the trial court and affirmed. The Supreme Court of the State of Oregon also agreed with the trial court that $10 million in punitive damages would violate the defendants' due process rights and affirmed the judgment of the trial court and the decision of the Court of Appeals. View "Trebelhorn v. Prime Wimbledon SPE, LLC" on Justia Law

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The case involves a plaintiff, Joni Fraser, who was attacked by two pit bulls owned by a tenant, Hebe Crocker, who rented a single-family residence from landlords Ali Farvid and Lilyana Amezcua. Fraser sued both Crocker and the landlords. After settling with Crocker, the case proceeded against the landlords. A jury found that the landlords had actual knowledge of the dangerous propensity of the dogs and could have prevented foreseeable harm to Fraser, awarding her damages exceeding $600,000. However, the trial court granted the landlords' motion for judgment notwithstanding the verdict (JNOV), finding no substantial evidence to demonstrate the landlords' knowledge of the dogs' dangerous propensities.Under California law, a landlord who lacks actual knowledge of a tenant's dog's vicious nature cannot be held liable when the dog attacks a third person. The Court of Appeal affirmed the trial court's ruling. The Court held that the email from a neighbor mentioning "guard dogs" did not constitute substantial evidence that the landlords knew or must have known the dogs were dangerous. The Court also rejected the plaintiff's argument that the landlords' alleged false statements denying knowledge of the dogs constituted evidence of their knowledge of the dogs' dangerous nature. The Court concluded that there was no direct or circumstantial evidence that the landlords knew or should have known the dogs were dangerous. View "Fraser v. Farvid" on Justia Law

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In this case from the Supreme Court of North Dakota, Ryan Kratz, who had entered into a purchase agreement to buy a business and building from Donald and Carol McIlravy, failed to make the agreed-upon payments. The McIlravys initiated two eviction actions, and a separate action seeking damages, cancellation of the contract, and release of funds held in a trust account. The district court initially dismissed one of the eviction actions, but eventually ruled in favor of the McIlravys, awarding them damages and ordering release of the trust funds. Several years later, Kratz filed a motion under Rule 60(b), alleging the district court lacked subject matter jurisdiction over the eviction actions and seeking to vacate or void all findings, conclusions, and orders, except the dismissals of the eviction actions. The district court denied this motion and awarded attorney’s fees to the McIlravys.On appeal, the Supreme Court of North Dakota held that Kratz's appeal was limited to the judgment denying his Rule 60(b) motion and that the motion was timely. The court determined that the district court had jurisdiction over the eviction cases and that any violation of N.D.R.Ct. 7.1(b)(1) was harmless error. The court also held that the district court did not abuse its discretion in awarding attorney’s fees. Consequently, the court affirmed the decision of the lower court. View "Don's Garden Center v. The Garden District" on Justia Law

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In this case, Epochal Enterprises, Inc., also known as Divine Orchids, entered into a commercial lease agreement with LF Encinitas Properties, LLC and Leichtag Foundation. The lease included a limitation of liability clause which stated that the defendants were not personally liable for any provisions of the lease or the premises, and the plaintiff waived all claims for consequential damages or loss of business profits. After the plaintiff sued the defendants, a jury found the defendants liable for premises liability and negligence.The jury awarded the plaintiff damages for lost profits and other past economic loss. However, the trial court granted the defendants’ motion for judgment notwithstanding the verdict (JNOV), reasoning that the lease agreement’s limitation of liability clause prevented the plaintiff from recovering the economic damages the jury awarded.The Court of Appeal, Fourth Appellate District Division One State of California, reversed the order granting JNOV in the defendants' favor, finding that the limitation of liability clause did not bar plaintiff’s recovery of damages. The court reasoned that the jury's award of damages necessarily implied a finding of gross negligence on the part of the defendants, which would be outside the scope of the indemnification clause. Further, the court held that the limitation of liability clause was void to the extent that it sought to shield the defendants from liability for their violations of the Health and Safety Code, as it violated public policy under Civil Code section 1668.On the defendants' cross-appeal regarding the damages award, the court affirmed the denial of the defendants' motion for partial JNOV, finding that substantial evidence supported the damages award. The court concluded that the jury could reasonably interpret the term "other past economic loss" on the verdict form as a different form of lost profits, and that the evidence presented to the jury provided a reasonable basis for calculating the amount of the plaintiff's lost profits. View "Epochal Enterprises, Inc. v. LF Encinitas Properties, LLC" on Justia Law

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In this case, residents of the Waples Mobile Home Park in Fairfax, Virginia, challenged the park's policy that required all adult tenants to provide proof of their legal status in the United States in order to renew their leases. The plaintiffs, four Latino families, argued that this policy violated the Fair Housing Act (FHA) because it disproportionately ousted Latinos from the park. The district court initially granted summary judgment in favor of the park, reasoning that the policy was necessary to avoid criminal liability under a federal statute prohibiting the harboring of undocumented immigrants.However, the United States Court of Appeals for the Fourth Circuit reversed the district court's judgment. The court of appeals found that the district court had misunderstood the federal anti-harboring statute. The court of appeals noted that the statute requires more than simply entering into a lease agreement with an undocumented immigrant to be in violation. Rather, a person must knowingly or recklessly conceal, harbor, or shield undocumented immigrants from detection. The court of appeals concluded that the park's policy of verifying tenants' legal status did not serve the park's stated interest of avoiding liability under the anti-harboring statute. Consequently, the park had not met its burden at the second step of the three-step burden-shifting framework established for disparate-impact claims under the FHA. As such, the court of appeals reversed the grant of summary judgment for the park and remanded the case to the district court for further proceedings. View "Reyes v. Waples Mobile Home Park Limited Partnership" on Justia Law