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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Wise v. Stonebridge Cmtys., LLC, 927 N.W.2d 772 (2019)

Citation
Wise v. Stonebridge Cmtys., LLC, 927 N.W.2d 772 (2019)
Parent Document
Wise v. Stonebridge Cmtys., LLC, 927 N.W.2d 772 (2019)
Jurisdiction
Minnesota (state)
Effective Date
2019-04-29

Other Sections in This Document (34)

Full Text

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The Wises argue, without citation to any supporting caselaw, that Stonebridge is liable in negligence for Wise's injuries because it violated the covenants under Minn. Stat. § 504B.161, subd. 1(a), by failing to repair the uneven sidewalk and failing to maintain the front entrance of the Graham Place Apartments, a common area on the premises. In effect, the Wises ask us to recognize a new statutory negligence cause of action. But it is not the function of this court to create new causes of action. Stubbs v. N. Mem'l Med. Ctr. , 448 N.W.2d 78, 81 (Minn. App. 1989), review denied (Minn. Jan. 12, 1990). Given the supreme court's instruction on the legislative intent of the covenants of habitability in Minn. Stat. § 504B.161, subd. 1(a), and the limited permitted methods of enforcing them, we hold that the covenants of habitability do not support a negligence cause of action by a tenant against a landlord for breach of its duty to repair and maintain the common areas of the leased premises. As a result, the district court did not err in granting summary judgment to Stonebridge on the Wises' claim of negligence under Minn. Stat. § 504B.161, subd. 1(a).