Abelmann v. SmartLease USA, L.L.C., 2014 ND 227

Abelmanns sued to evict SmartLease from farmland leased for RV/mobile park use.
District court denied eviction, finding any breaches were minor and non-essential; no adequate findings on rent or material breaches.
Lease (Dec 18, 2011) permitted RV/mobile park use and required high-quality, clean, professional management.
Addendum (Nov 10, 2012) extended renewal and granted a long-term option to purchase; Ranger Rock agreement formed later.
Abelmanns alleged multiple breaches (rent, management, facilities) and termination notice; SmartLease claimed substantial development and profit; trial record lacked specific findings.
Court of Appeals reversed and remanded for adequate findings, emphasizing contract language and proper interpretation of lease purpose.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the lease’s stated purpose was properly interpreted	Abelmanns: lease requires high-quality RV park use.	SmartLease: focus on profit and development suffices.	District court erred in interpreting lease purpose; remand for proper findings.
Whether there were material breaches of the lease	Abelmanns: multiple material breaches (rent, management, facilities).	SmartLease: any noncompliance was minor/non-essential.	Court failed to determine material breaches; remand for adequate findings.
Whether eviction was proper based on rent nonpayment for three days	Abelmanns: rent was unpaid as of due date triggering eviction.	SmartLease: any delay was not a material breach.	Remand to make explicit findings on rent payment timing and material breach.

VND, LLC v. Leevers Foods, Inc., 2003 ND 198 (2003 ND) (contract interpretation; factual basis for eviction ruling; leases treated as contracts)
Kolling v. Goodyear Tire and Rubber Co., 272 N.W.2d 54 (ND 1978) (substantial performance; contract construction governs lease disputes)
Schmidt v. Schmidt, 2003 ND 55 (2003 ND) (standard for clearly erroneous findings; review of fact findings under 52(a))