Ficker v. Diefenbach

578 P.2d 467, 34 Or. App. 241, 1978 Ore. App. LEXIS 2958
Court of Appeals of Oregon·Decided August 22, 1978·No. 167-559, CA 8956·Published·Cited by 4 cases

Opinion

*243 BUTTLER, J.

Defendant appeals from a judgment for plaintiff entered in a Forcible Entry and Detainer (FED) proceeding. 1 Plaintiff has not appeared in this court.

Commencing in October, 1971, defendant rented, on a month-to-month basis, a house owned by plaintiff. The chimney on the house had a crack in it as a result of the Columbus Day storm in 1962. Starting October 1, 1972, and on each October 1 through October 1, 1976, defendant sent a letter to plaintiff complaining of the cracked chimney, stating that it constituted a fire danger. The assessed value of the property for tax purposes was increased to $16,000 for the tax year 1976-77; for the tax year 1975-76 the assessed value was $11,750, and for the preceding year it was $10,790. Plaintiff decided to sell the property and on November 3, 1976, notified defendant of that fact. Defendant would not permit plaintiff in the house in order to show it to prospective purchasers, but made two offers to purchase the property for $10,500 — the first on contract with $500 down, and the second for cash. Neither offer was accepted.

The house was not sold by the end of December, and plaintiff notified defendant on December 29, 1976, that the rent would increase as of February 1,1977, to $165 per month because of the increase in assessed value; it had formerly been $110 per month.

On January 26,1977, the chimney showed evidence of further deterioration and defendant notified the local fire inspector. On February 5, 1977, defendant enclosed a check in the amount of $117.50 as rental for February with a letter stating that the amount of the check "represents the legal one percent (1%) of the assessed valuation of this property for the tax year 1975-6.” The letter went on to state that the assessed valuation of $16,000 for 1976-77 "is illegal and contrary to law,” because there had been no "proof of *244 actual and substantial improvements.” It is clear from that letter that defendant understood the basis for the rent increase and accepted as a formula for determining rental an amount equal to 1% of assessed value. 2 The letter further reminded plaintiff of the condition of the chimney and advised him of an inspection by the fire marshal.

Plaintiff returned the check immediately and demanded the full rental amount of $165. No mention was made of the chimney. On February 11, 1977, defendant had the chimney repaired at her own expense. 3 On February 14, 1977, defendant filed a complaint with the Bureau of Labor alleging that plaintiff had discriminated against her with respect to housing on account of her sex. On February 22,1977, no rental payment having been received by plaintiff, a 30-day notice to vacate the premises was served on defendant, and on February 28, 1977, defendant complained to the Bureau of Buildings, Electrical Division, which sent plaintiff a "Notice of Violation of City Ordinance.” 4

On March 28, 1977, this FED proceeding was commenced. Defendant’s answer alleged eight "affirmative defenses and counterclaims” under the Oregon Residential Landlord and Tenant Act. ORS *245 91.700-91.895 (ORLTA). In each of five counterclaims, defendant claimed damages for "mental distress” in varying amounts. Plaintiffs demurrer to those counterclaims was sustained on the ground that such damages were not allowable under ORLTA. That ruling is the basis for defendant’s first assignment of error.

Defendant does not refer us to any language in ORLTA which specifically authorizes damages for mental distress, and we have found none. She relies heavily on ORS 91.725(1), which provides:

"The remedies provided by ORS 91.700 to 91.895 shall be so administered that an aggrieved party may recover appropriate damages. The aggrieved party has a duty to mitigate damages.”

A reading of ORLTA as a whole indicates that in most, if not all, instances the damages for which provision is made are expressed in terms which may be readily computed to liquidated amounts. Examples are: ORS 91.745(2), "actual damages” plus "an amount up to three months’ periodic rent”; 91.760(8), "an amount, equal to twice the amount wrongfully withheld”; 91.815, "an amount not more than two months’ periodic rent or twice the actual damages sustained by him, whichever is greater.” 5

In any dispute where one or both parties claim the other violated a legal duty, whether contractual or statutory, there is very likely to be emotional disturbance or mental distress suffered by each of the parties. This would be even more likely with respect to the residential landlord and tenant relationship. If damages for mental distress were intended to be recoverable, they would be most appropriate where the wrong *246 is deliberate, grossly negligent or malicious. 6 Yet the two sections which deal specifically with such conduct do not authorize such damages. ORS 91.840(4) provides that "[ijn'the event of deliberate and malicious violation the landlord shall be liable for twice the actual damages sustained by the tenant.” ORS 91.805(1) and (2) 7 carefully circumscribe damages recoverable for the landlord’s deliberate refusal or grossly negligent failure to supply any "essential service.” 8

Defendant would have us ignore the foregoing specific provisions for damages in given situations, *247 and hold that in any case where the landlord violates ORS 91.770 (requiring a landlord to maintain premises in habitable condition) the tenant may recover "damages” under ORS 91.800(2), which provides:

"Except as provided in ORS 91.700 to 91.895, the tenant may recover damages and obtain injunctive relief for any noncompliance by the landlord with the rental agreement or ORS 91.770.”

We have held that ORS 91.800

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Ficker v. Diefenbach, 578 P.2d 467, 34 Or. App. 241, 1978 Ore. App. LEXIS 2958 (Or. Ct. App. 1978).

578 P.2d 467 (Ficker v. Diefenbach) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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