Michael Mueller v. Rodney Conaway, A-0421-23

The case involves a landlord-tenant dispute between Michael Mueller (landlord) and Rodney Conaway (tenant) concerning a Section 8-subsidized apartment in Bound Brook, NJ.
The lease began on February 1, 2020, and was renewed annually through February 1, 2023.
The dispute originated over a rent increase, with plaintiff seeking $145 more per month instead of the $35 approved by Section 8, attributing the excess to pet fees for defendant’s three dogs. Conaway refused to pay the disputed portion.
Two eviction actions were filed; the first was dismissed for lack of proper Section 8 notification, and the second ended in a settlement, requiring Conaway to vacate by December 31, 2022.
Conaway remained until March 9, 2023. Mueller sued for property damage and unpaid rent for January–March 2023; Conaway counterclaimed for discrimination and other alleged harms. The trial court ruled primarily for plaintiff but failed to adjudicate most of Conaway's counterclaims.
On appeal, the appellate court affirmed in part, reversed the finding that defendant was a holdover tenant for January and February 2023, and remanded for adjudication of Conaway’s counterclaims and recalculation of damages/security deposit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Status as holdover tenant (Jan-Feb 2023)	Defendant was a holdover tenant after Dec 31, 2022	He paid rent as allowed by a court order, not a holdover	Not a holdover tenant in Jan-Feb; error to offset security deposit
Damages for March 2023	Entitled to unpaid rent and damages for defendant’s overstay	No specific dispute on March rent, conceded nonpayment	Defendant potentially liable for double rent for 9 days in March
Counterclaims	Claims were out of scope or adequately addressed	Court failed to adjudicate counterclaims on the merits	Remanded for trial court to consider counterclaims
Security deposit offset	Security deposit should be credited to landlord for unpaid rent	Should be returned; only March possibly claimable	Security deposit offset must be properly recalculated

State v. Pierre, 223 N.J. 560 (N.J. 2015) (de novo review for legal conclusions)
Gnall v. Gnall, 222 N.J. 414 (N.J. 2015) (deference to trial court factual findings)
Newark Park Plaza Assocs., Ltd. v. City of Newark, 227 N.J. Super. 496 (N.J. Super. Ct. Law Div. 1987) (holdover tenant defined and governed)
Lorril Co. v. La Corte, 352 N.J. Super. 433 (N.J. Super. Ct. App. Div. 2002) (holdover statute's penal nature and application principles)
Heyman v. Bishop, 15 N.J. Super. 266 (N.J. Super. Ct. App. Div. 1951) (rights of holdover tenants governed by expired lease)