Bass v. Equity Residential Holdings, LLC
2014 Minn. App. LEXIS 64
| Minn. Ct. App. | 2014Background
- Bass, a tenant of Equity, fell behind on rent and Equity filed eviction; a hearing was conditioned on Bass depositing $960, but she did not, and equity sought recovery of premises with a writ that was never issued.
- Bass’s locks were changed after she left for work; Frenz disposed of her belongings in dumpsters claiming abandonment.
- Bass filed a lockout petition under Minn.Stat. § 504B.375; referee found Equity defaulted, Bass not abandoned, and damages to be determined at a separate damages hearing.
- Referee awarded treble damages under § 504B.231 and $1,000 in punitive damages under § 504B.271, totaling $10,386.97 plus interest, fees, and costs; Equity sought district court review.
- District court reviewed the referee’s decision, upheld it, and entered judgment for Bass on November 7, 2013; Equity appealed to the Minnesota Court of Appeals.
- The housing court is within the district court structure and has jurisdiction over proceedings under chapter 504B and related landlord-tenant damage actions; the district court has original jurisdiction over civil actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Housing court jurisdiction to award monetary and punitive damages | Bass contends housing court authority extends to monetary awards under 504B. | Equity argues housing court is limited and cannot award monetary damages. | Housing court has jurisdiction; district court can confirm damages. |
| Damages calculation and award validity | Bass’s proofs support treble damages and punitive damages for bad faith ouster and property loss. | Equity contends insufficient proof, improper mitigation, and improper combination of damages regimes. | District court findings supported; treble and punitive damages properly awarded for distinct statutory violations. |
Key Cases Cited
- Griffis v. Luban, 601 N.W.2d 712 (Minn.App.1999) (referee findings adopted by district court become district court findings)
- Rasmussen v. Two Harbors Fish Co., 882 N.W.2d 790 (Minn.2013) (standard of review for findings of fact)
- Deutz-Allis Credit Corp. v. Jensen, 458 N.W.2d 163 (Minn.App.1990) (mitigation duty to minimize damages)