DEUTSCHE BANK NAT. TRUST CO. v. Kevlik, 20 A.3d 1002

Deutsche Bank National Trust Company filed a landlord and tenant writ seeking possession of property in Chester, arguing ownership and entitlement to possession after a foreclosure sale.
Defendants Kevlik and Durgin alleged no foreclosure sale occurred and challenged the plaintiff's title to the property.
At merits, plaintiff offered uncertified documents (foreclosure deed, assignment, and mortgage assignment) and an unauthenticated 'affidavit of ownership'; defendants objected to authenticity.
The trial court admitted the documents over objections and the plaintiff's counsel acknowledged lack of firsthand knowledge about the foreclosure, payments, and ownership.
Defendants argued video evidence showed no foreclosure sale; the court refused to consider it and ordered judgment for plaintiff; $348.84 was later paid into court.
On appeal, the court reversed, holding the plaintiff failed to prove ownership under RSA 540:12 because the evidence was unauthenticated and not properly admitted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was ownership proven for possessory relief under RSA 540:12?	Kevliks lacked title evidence; ownership shown by foreclosure documents.	Pltf failed to prove ownership; documents were unauthenticated and insufficient.	No; ownership not proven; reversed judgment for plaintiff.
Were the foreclosure documents admissible to prove ownership?	Uncertified documents suffice to prove ownership.	Documents were unauthenticated hearsay; not admissible.	Error to admit reliance on uncertified, unauthenticated documents.
Could plaintiff rely on an unauthenticated 'affidavit of ownership'?	Affidavit certified ownership of the property.	Affidavit not notarized, not signed under oath, unsigned by proper author.	Not admissible; trial court erred in admitting and relying on it.
Should the court have allowed title challenges in district court or required a title action in superior court?	Title issues should be outside the district court's scope; possession warranted.	Title challenges belong in superior court; plaintiff could not proceed otherwise.	Trial court erred; title issues require superior court action if contested.

Liam Hooksett, LLC v. Boynton, 157 N.H. 625 (N.H. 2008) (ownership proof required for possessory action under RSA 540:12; unauthenticated documents insufficient)
Bank of N.Y. Mellon v. Cataldo, 161 N.H. 135 (N.H. 2010) (title action constraints; district court limitations on title issues in landlord-tenant proceeding)
Kenison v. Dubois, 152 N.H. 448 (N.H. 2005) (statutory interpretation; plain meaning; de novo review of statute)