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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Lindquist v. Stella, 111 N.E.3d 304 (2018)

Citation
Lindquist v. Stella, 111 N.E.3d 304 (2018)
Parent Document
Lindquist v. Stella, 111 N.E.3d 304 (2018)
Jurisdiction
Massachusetts (state)
Effective Date
2018-09-10

Full Text

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In light of this evidence, and after reviewing the record as a whole, we are unable to determine the basis for the judge's finding that the issues documented by the inspectors in 2016 existed "since the inception of the tenancy." "[N]ot every defect gives rise to a diminution in rental value," McKenna v. Begin, 5 Mass. App. Ct. 304, 308 (1977), and even "the existence of a code violation by itself does not necessarily entitle a tenant to a finding that a material breach of the warranty of habitability has occurred." South Boston Elderly Residences, 91 Mass. App. Ct. at 463-464. The judge did not grapple with the issue of when the defects in the porches became serious enough to rise to the level of a material breach. We therefore remand this claim for further findings and recalculation of damages, including whether multiple damages and attorney's fees are warranted under G. L. c. 93A.