Cent. Hous. Assocs., LP v. Olson, 929 N.W.2d 398 (2019)

Citation: Cent. Hous. Assocs., LP v. Olson, 929 N.W.2d 398 (2019)
Parent Document: Cent. Hous. Assocs., LP v. Olson, 929 N.W.2d 398 (2019)
Jurisdiction: Minnesota (state)
Effective Date: 2019-06-12
Original Source: https://www.courtlistener.com/opinion/8288834/cent-hous-assocs-lp-v-olson/ ↗

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We begin with the question of whether Olson is entitled to assert a retaliation defense under Minn. Stat. § 504B.441 to CHA's breach-of-lease eviction action. We must interpret the statute, a question of law that we review de novo. Cocchiarella v. Driggs , 884 N.W.2d 621, 624 (Minn. 2016). The purpose "of all statutory interpretation is to ascertain and effectuate the intent of the Legislature." Hous. & Redevelopment Auth. of Duluth v. Lee , 852 N.W.2d 683, 687 (Minn. 2014) ; see also Minn. Stat. § 645.16 (2018). We will apply the plain meaning of a statutory provision "[i]f the Legislature's intent is clear from the unambiguous language of the statute." Staab v. Diocese of St. Cloud , 853 N.W.2d 713, 716-17 (Minn. 2014). Consistent with our canons of statutory interpretation, "we construe technical words and phrases 'according to [their] special meaning,' and other words and phrases according to their 'common and approved usage.' " Cocchiarella , 884 N.W.2d at 624 (alteration in original) (quoting Staab v. Diocese of St. Cloud , 813 N.W.2d 68, 72 (Minn. 2012) ); see also Minn. Stat. § 645.08(1) (2018).

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