Nitardy, J. & L. v. Chabot, M.

CourtSuperior Court of Pennsylvania
DecidedSeptember 14, 2018
Docket599 MDA 2017
StatusPublished

This text of Nitardy, J. & L. v. Chabot, M. (Nitardy, J. & L. v. Chabot, M.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nitardy, J. & L. v. Chabot, M., (Pa. Ct. App. 2018).

Opinion

J-A32031-17

2018 PA Super 255

JOHN NITARDY AND : IN THE SUPERIOR COURT OF LAURIE NITARDY, : PENNSYLVANIA : Appellees : : v. : : MICHAEL CHABOT, : : Appellant : No. 599 MDA 2017

Appeal from the Judgment Entered March 7, 2017, in the Court of Common Pleas of Centre County Civil Division at No(s): 2014-4542

BEFORE: OTT, DUBOW, and STRASSBURGER,* JJ.

CONCURRING AND DISSENTING OPINION BY STRASSBURGER, J.:

FILED SEPTEMBER 14, 2018

I respectfully dissent from the learned Majority’s holding as to

Landlord’s second and fourth issues (i.e., the sufficiency of the written list

and Landlord’s counterclaim for damages). In my view, Landlord’s list of

damages satisfied, by a bare minimum, the requirements of 68 P.S. §

250.512(a). Further, even if the Majority were correct that the Landlord’s

list of damages was insufficient, the Majority’s remand instructions relating

to Landlord’s second issue and disposition of Landlord’s counterclaim in

Landlord’s fourth issue are at odds with 68 P.S. § 250.512(b). I join the

learned Majority’s Opinion in all other aspects, including the first and third

issues presented by Landlord (i.e., the oral modification of the lease to end

* Retired Senior Judge assigned to the Superior Court. J-A32031-17

mid-month and the inapplicability of the safe harbor provision in 68 P.S. §

250.512(e)).

I turn first to the sufficiency of Landlord’s written list of damages. The

Majority concludes that Landlord’s list failed to satisfy subsection 250.512(a)

because Landlord gave a generalized description of the damage for some of

the items on the list and/or provided generalized and/or unspecified damage

estimates for others. Majority Opinion, at 12.

The Landlord and Tenant Act (the Act) requires the following regarding

a written list of damages.

(a) Every landlord shall within thirty days of termination of a lease or upon surrender and acceptance of the leasehold premises, whichever first occurs, provide a tenant with a written list of any damages to the leasehold premises for which the landlord claims the tenant is liable. Delivery of the list shall be accompanied by payment of the difference between any sum deposited in escrow, including any unpaid interest thereon, for the payment of damages to the leasehold premises and the actual amount of damages to the leasehold premises caused by the tenant. ...

68 P.S. § 250.512(a). The Act does not define or further describe the term

“written list of damages” referred to in subsection 250.512(a), and there are

no reported decisions by this Court or our Supreme Court interpreting this

term.

I agree with the trial court that, because the landlord must return the

difference between the security deposit and the actual damages caused by

the tenant along with the written list for damages, implicit in that

requirement is that the landlord must assign specific values to items of

-2- J-A32031-17

damage. However, I disagree that Landlord’s list emailed to Tenants on July

19, 2014 (Updated List of Damages) fails to constitute a written list for

damages within the meaning of subsection 250.512(a).

In his Updated List of Damages, Landlord did assign monetary values

to nine of the items. See Landlord’s Trial Exhibit D-6 at 2 (listing “Light bulb

$8.45”; “Lawn repair $34.81”; “AC filter 18.01”; “Chair repair $2.10”; “Foyer

fix $900.00”; and “Porch fix $900.00”). He also assigned monetary values

to seven additional items, albeit in lump sums combining unrelated items

together. See id. (listing “Dog hair cleaning, smell removal, and attempt at

foyer repair using fillers $300.00”; “Wall damage repair, painting to cover up

marks, handrail repair, counter top repair $1,800”). While assigning a

separate value to each item of damage would be preferable for clarity’s

sake, the Majority and the trial court reads such a requirement into the Act

when the Act does not impose such a requirement.

The Majority correctly observes that Landlord failed to provide a

monetary value for three items. See id. (listing “Carpet repair:?”; “Cabinet

stains: ?”; “Shrub damage:?”). However, the aggregate amount of the

estimated damages that Landlord did list totaled $4,054.37. Trial Court

Opinion and Order, 12/7/2016, at 6. This alleged amount of damage clearly

exceeded Tenants’ entire security deposit, which was $3,600. See Lease

Agreement at ¶ 8. The purpose of subsection 250.512(a) is to ensure that a

landlord promptly returns all portions of the security deposit that exceed

-3- J-A32031-17

actual damages. See 68 P.S. § 250.512(a). Given that Landlord’s overall

damage estimate exceeded the security deposit amount, in my view, the fact

that Landlord did not include estimates for every item of damage does not

mean that Landlord’s list fails to satisfy subsection 250.512(a) altogether.

Furthermore, while some of Landlord’s descriptions would benefit from

more detail and clarity, when read in context with his prior communications

with Tenants and the email as a whole, Landlord’s Updated List of Damages

achieved the purpose of putting Tenants on notice as to the damages

Landlord believes they caused. For example, Landlord’s reference to a

“foyer fix” in the Updated List of Damages is vague, but earlier in the email,

he described specific items of damage to the foyer. See Landlord’s Trial

Exhibit D-6 at 1 (describing “[w]ood foyer covered in dog claw scratches,

some that dented the underlying wood”).

Thus, I conclude that the trial court erred in determining that Landlord

failed to send a timely written list of damages to Tenants that satisfied the

requirements of subsection 250.512(a). To conclude otherwise would

necessitate reading requirements into the Act that do not exist. If the

legislature had intended the level of specificity and organization in the

description of the damages contemplated by the trial court and the Majority,

it would have used language imposing such a requirement. Moreover, the

thirty-day timeframe provided by subsection 250.512(a) is not a long period.

In many cases, it would be impossible to assemble estimates from

-4- J-A32031-17

contractors in this timeframe, especially if there is extensive damage to the

property. Once the landlord has accounted for damages that exceed the

security deposit, I do not believe the Act requires the landlord to provide an

exhaustive list of every single item of damage to the property and the exact

amount of the repairs within thirty days. Thus, I would find that Landlord’s

Updated List of Damages satisfies the requirements of subsection

250.512(a) by a bare minimum.1

I further part company with the Majority regarding its remand

instructions to the trial court and its handling of Landlord’s counterclaim for

damages. Even if the Majority were correct that Landlord’s Updated List of

Damages failed to satisfy the requirements of subsection 250.512(a), I

respectfully disagree with the Majority’s conclusion about the consequences

of such noncompliance.

After holding that Landlord failed to comply with subsection

250.512(a), the Majority concludes that Tenants are entitled to double the

amount of their security deposit less any actual expenses as provided in

subsection 250.512(c). Majority Opinion, at 12.

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