Fritz v. Warthen, 298 Minn. 54 (1973)

Holding:
Minnesota Supreme Court adopted the implied covenants of habitability and adopted them as defenses to nonpayment summary proceedings — among the earliest statewide adoptions of the warranty in the U.S. Codified thereafter as Minn. Stat. § 504B.161 (covenants of habitability) and the rent-escrow procedure of § 504B.385. Tenants may abate rent, deposit rent into court under § 504B.385 (rent escrow), or pursue a tenant-remedies action under § 504B.395 to compel repairs.