Cent. Hous. Assocs., LP v. Olson, 910 N.W.2d 485 (2018)

Citation: Cent. Hous. Assocs., LP v. Olson, 910 N.W.2d 485 (2018)
Parent Document: Cent. Hous. Assocs., LP v. Olson, 910 N.W.2d 485 (2018)
Jurisdiction: Minnesota (state)
Effective Date: 2018-04-09
Original Source: https://www.courtlistener.com/opinion/8283559/cent-hous-assocs-lp-v-olson/ ↗

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We add that reading the retaliation provision in subdivision 2 to apply to evictions based on termination for a breach of lease would disregard a common maxim in statutory construction. Whenever possible, we will not interpret a statute in a manner that fails "to give effect to all of its provisions" so as to render any "word, phrase, or sentence ... superfluous, void, or insignificant." See Am. Family Ins. Grp. v. Schroedl , 616 N.W.2d 273, 277 (Minn. 2000) (quotation omitted). Construing the retaliation provision in subdivision 2 to apply to evictions based on breach of the lease would effectively nullify subdivision 4, which states, "Nothing contained in subdivisions 2 and 3 limits the right of the landlord pursuant to the provisions of subdivision 1 to terminate a tenancy for a violation by the tenant of a lawful, material provision of a lease or contract...."

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