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Phillips Neighborhood Housing Trust v. Brown

Court of Appeals of Minnesota
1997 WL 307037, 1997 Minn. App. LEXIS 612, 564 N.W.2d 573 (1997)
ELI5:

Rule of Law:

When a lease agreement explicitly prohibits illegal activity on the premises and provides for termination as a remedy, a landlord may evict all co-tenants for a material breach of the lease, even if only one co-tenant committed the illegal act and the others were unaware.


Facts:

  • Mary Brown and her 20-year-old son, Anthony Brown, jointly applied for and became co-tenants of an apartment owned by Phillips Neighborhood Housing Trust (PNHT), which provides federally subsidized housing.
  • Both Mary and Anthony Brown signed a lease agreement after PNHT management reviewed the regulations with them.
  • The lease explicitly prohibited residents, their families, or guests from engaging in any unlawful activity and stated that a violation was a material breach, giving PNHT the option to cancel the lease and evict.
  • Mary Brown stated she wanted her son to live with her so she could maintain more control over him.
  • Less than a week after moving in, police were called to the apartment and found crack cocaine, which belonged to Anthony Brown.
  • It is undisputed that Mary Brown and her minor daughters, who also lived in the apartment, had no knowledge of the drugs.

Procedural Posture:

  • Phillips Neighborhood Housing Trust (PNHT) brought an unlawful detainer action against Mary Brown and Anthony Brown to recover possession of the apartment.
  • A housing referee for the trial court found in favor of the landlord, PNHT.
  • Mary Brown sought judicial review of the referee's decision in the district court.
  • The district court affirmed the referee's decision in favor of PNHT.
  • Mary Brown, as appellant, appealed the district court's decision to this intermediate appellate court; PNHT is the respondent.

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Issue:

Does a landlord have the right to bring an unlawful detainer action to recover possession of a premises when one of two co-tenants engages in illegal drug activity in violation of the lease, even if the other co-tenant was not aware of the activity?


Opinions:

Majority - Judge Harold W. Schultz

Yes. A landlord may bring an unlawful detainer action to recover possession under these circumstances. The court's reasoning is based on a straightforward interpretation of the lease as a contract. The lease clearly prohibited illegal activity by any resident, and Anthony Brown, as a signatory and resident, violated this provision. This violation gave the landlord, PNHT, the contractual right to exercise its option to cancel the lease and evict all tenants. The court rejected the argument that the lease should be rewritten to remove only the offending tenant, holding that the landlord is entitled to have its lease enforced as written. Mary Brown's innocence is not a defense, as her right to possession derives solely from the lease that her co-tenant breached. Furthermore, the court recognized a strong public policy interest in eliminating drugs from subsidized housing and ensuring a safe environment for all tenants, viewing eviction as the landlord's most effective means to achieve this.



Analysis:

This decision solidifies the principle that lease provisions in subsidized housing will be strictly enforced, particularly those related to illegal drug activity. It effectively rejects an 'innocent tenant' defense, establishing that the misconduct of one co-tenant can result in the eviction of an entire household. The ruling prioritizes the landlord's contractual rights and the broader public policy goal of maintaining safe, drug-free housing over the hardship faced by an individual tenant who was not personally culpable for the lease violation. This creates a form of strict liability for tenants, holding them responsible for the actions of all household members listed on the lease.

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