JP Morgan Chase Bank, NA v. Grimes, 114 A.3d 1007

Plaintiff JP Morgan Chase Bank acquired 54 Whitney Street by foreclosure on May 27, 2011; the property is "restricted property" under RSA 540:1-a.
On July 25, 2013, plaintiff served defendant Heilan Grimes a 90-day Notice to Quit pursuant to RSA 540:2, citing "other good cause" because the owner "desires to market, sell and/or convey the property in a vacant condition."
Defendant disputed that the stated reason constituted statutory "other good cause."
Trial court found the plaintiff's stated reason satisfied RSA 540:2, II(e) and granted a writ of possession; plaintiff later sold the property to a third party (uncontested).
On appeal the sole issue was whether a desire to market/sell/convey a restricted property vacant qualifies as "other good cause" to terminate a tenancy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does a landlord's desire to market/sell/convey a restricted property vacant qualify as "other good cause" under RSA 540:2, II(e)?	Such a desire is a legitimate economic/business reason and therefore falls within "other good cause."	"Other good cause" is ambiguous and prior case law/legislative intent exclude the plaintiff's reason.	Yes. Under these facts (foreclosure purchaser seeking to sell free of tenants), the desire to market/sell/convey vacant is "other good cause."

Great Traditions Home Builders v. O’Connor, 157 N.H. 387 (2008) (court is final arbiter of statutory intent and starts with plain meaning of statute)
AIMCO Props. v. Dziewisz, 152 N.H. 587 (2005) (held that mere lease expiration to replace a tenant with a like tenant was not "other good cause")
Bedford Chapter–Citizens for a Sound Economy v. Sch. Admin. Unit #25, 151 N.H. 612 (2004) (if statute is plain, no need to look beyond text)
State v. Whittey, 149 N.H. 463 (2003) (use legislative history when statute is ambiguous)