Skip to main content
DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Sherryland, Inc. v. Snuffer, 150 N.H. 262 (2003)

Citation
Sherryland, Inc. v. Snuffer, 150 N.H. 262 (2003)
Parent Document
Sherryland, Inc. v. Snuffer, 150 N.H. 262 (2003)
Jurisdiction
New Hampshire (state)
Effective Date
2003-11-21

Full Text

1,523 chars
RSA 540:13-a (1997) allows a tenant to defend an eviction action upon proof that an eviction was sought in retaliation for “reporting in good faith what the tenant reasonably believe[d] to be ... an unreasonable and substantial violation of a regulation or housing code to the landlord or any board, agency or authority ... as to the reasonable fitness of... property for health or safety.” RSA 540:14, II provides that whenever the tenant successfully raises the defense of retaliation, “damages of not more than 3 months’ rent may be awarded.” (Emphasis added.) The statute does not require a tenant to plead or prove damages, but rather authorizes an award of damages against a landlord when an eviction action is sought in retaliation for a specified complaint. See Carter v. Lachance, 146 N.H. 11, 14 (2001). In Carter, we ruled that a statutory minimum award was not based upon actual damages suffered, but was a penalty imposed upon landlords who violated RSA 540-A:3 (Supp. 2002), which prohibits certain acts by landlords. Id. Thus, recovery did not require any evidence of damages, but only a finding that the landlord did, in fact, violate the statute. Id. Similarly, once the prerequisite of retaliation is satisfied, RSA 540:14, II allows the trial court to impose a penalty on landlords without requiring any proof of damages by the defendant. In this case, the trial court found retaliation. Accordingly, it was permitted to award the defendant $894.00 in damages, exactly three times her monthly rental fee.