A Minnesota appeals court has ruled that a landlord’s decision to padlock a tenant’s apartment following a nearby fire was an unlawful eviction. The decision emphasizes that landlords cannot deny tenants access to their homes without following the proper legal process, even when a unit is deemed temporarily uninhabitable by city officials. The case now heads back to a lower court to determine damages and compensation owed to the tenant.
Fire Leads to Lockout Dispute
Tyrone Murphy, a long-term tenant of over a decade in a New Hope apartment, found himself locked out of his unit in July 2022 after a fire broke out on a neighbor’s balcony. Although the fire spread to his apartment and led the city to declare it uninhabitable until repairs were made, the landlord’s decision to place a padlock on the door sparked a legal battle.
City Notice Did Not Require Padlocking
After the fire, the city of New Hope posted a notice on Murphy’s apartment stating it could not be occupied until repairs were completed and inspected. However, the city never instructed or authorized the landlord to padlock the unit. Despite this, the landlord proceeded to secure the apartment without a court order, a move the court later ruled was unlawful.
Landlord Cites Safety, Claims Voluntary Access
Steven Scott Management Inc. and Kings Manor LLC, who manage the property through Aeon, argued that the padlock was installed to prevent the tenant from occupying an unsafe unit. Their attorney, Christopher Kalla, likened the situation to wildfire-affected homes where residents are barred from entering. He claimed that Murphy could have contacted the management to arrange retrieval of his belongings.
Tenant Forced Into Unstable Living Conditions
Murphy testified that after discovering the padlock, he stayed in hotels and his car while the apartment was being repaired. He reported missing work and having to replace essential items such as clothes and hygiene products. A couple of weeks later, he filed a lockout petition and an Emergency Tenant Remedies Action (ETRA), seeking alternative housing costs and compensation for his losses.
Lower Court Initially Rejected Tenant’s Claim
While a referee recommended in favor of Murphy, stating that the landlord committed an unlawful lockout and owed him compensation, the district court disagreed. It ruled that either the situation did not qualify as a lockout or that the lockout was justified by the city’s declaration. The court also stated that the ETRA statute did not support monetary damages or a requirement for the landlord to cover alternate housing when the fire was not their fault.
Appeals Court Reaffirms Tenant Rights
The Minnesota Court of Appeals reversed the lower court’s ruling. Judge Rachel Bond, writing for the court, emphasized that a landlord cannot evict or lock out a tenant without going through the courts, regardless of the circumstances. The court clarified that offering the tenant a chance to collect their belongings does not justify denying them access to their home without legal proceedings.
Legal Experts Stress Prohibition on Self-Help Evictions
Murphy’s attorney, Erica Holzer of Maslon LLP, highlighted that Minnesota law strictly prohibits self-help evictions. She argued that even if a tenant cannot live in the unit due to safety concerns, landlords still must follow judicial procedures before restricting access. “What a landlord cannot do, no exceptions, is put a padlock on that tenant’s door,” she said. The appeals court remanded the case to the district court to determine the amount of damages Murphy should receive. These could include costs for temporary housing and other losses Murphy experienced during the lockout. The court clarified that ETRA allows for such compensation in cases of unlawful exclusion.
