Geldhof v. Penwood Associates, 119 N.H. 754 (1979)

Mr. and Mrs. Joseph Geldhof rented an apartment from Penwood Associates, Inc., on September 11,1976. The parties executed a lease under which the tenant gave the landlord $140 as a security deposit. The lease did not mention interest. On September 13, 1977, the legislature enacted RSA 477:48 (Supp. 1977). Eight months later the parties terminated the tenancy and Penwood, after deducting certain sums from the deposit, and without calculating any interest, returned the remainder to the Geldhofs. Mr. Geldhof then brought an action in Concord District Court to recover the interest accumulated between the effective date of RSA 477:48 (Supp. 1977) and the end of the lease, and for other relief not germane to this appeal. The District Court (Waters,