Ostlund v. Hendricks

615 P.2d 327, 289 Or. 543, 1980 Ore. LEXIS 1060
CourtOregon Supreme Court
DecidedJuly 24, 1980
DocketTC 14763-D, CA 14768, SC 26776
StatusPublished
Cited by8 cases

This text of 615 P.2d 327 (Ostlund v. Hendricks) is published on Counsel Stack Legal Research, covering Oregon Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ostlund v. Hendricks, 615 P.2d 327, 289 Or. 543, 1980 Ore. LEXIS 1060 (Or. 1980).

Opinion

LENT, J.

The legal issue presented is whether the notice of termination required by ORS 91.885 for termination of a rental agreement for a mobile home space must contain a "designated date” for termination. The following are the facts which present this issue.

The plaintiff is manager and owner of a mobile home park. On December 14, 1974, defendant signed an agreement for a month to month rental of a space for a mobile home. Plaintiff’s attorney wrote defendant a letter dated December 12,1978, informing her that she was in violation of her tenancy agreement in several particulars.1 The letter concluded:

"You are hereby given notification of these violations of your tenancy agreement. If they are not corrected within thirty (30) days of your receipt of this letter, as allowed by law, legal proceedings will be commenced to remove you from Nut Tree.
"It is Mrs. Ostlund’s hope that you will comply thereby avoiding any unpleasantness and additional expense. The park rules are for the benefit of all the [546]*546tenants. They are designed to make the park an attractive and comfortable place to live. Your failure to comply hurts all the other tenants within the park and cannot be tolerated.
"Incidentally, in the past, your rent payment has often been late. In the future, no further late rent payments will be accepted.”

The plaintiff filed a Forcible Entry and Detainer (FED) complaint on February 1,1979, attaching and incorporating the letter delivered to defendant. The matter went to trial in the district court and judgment was entered for plaintiff. The defendant appealed to the Court of Appeals which held that plaintiff’s letter as a matter of law complied with the notice requirements of ORS 91.885. Ostlund v. Hendricks, 43 Or App 891, 607 P2d 1191 (1979). This court allowed review, ORS 2.520, 288 Or 633 (1980). We reverse the Court of Appeals.

The defendant contends that the FED complaint fails to state a cause of action because the letter incorporated in the complaint was not a notice of termination as required by the statutes discussed below. Resolution of this issue requires a journey through a number of Oregon statutes.

A rental agreement for a mobile home space is governed by the Residential Landlord and Tenant Act, ORS 91.700 to 91.895 (hereinafter "the landlord tenant act”). ORS 91.705(3); 91.715. ORS 105.120(2)2 provides that a FED action for recovery of premises subject to the landlord tenant act may be maintained when notice to terminate has been given "in the manner prescribed by ORS 91.855.”

[547]*547At the outset we note an area of confusion in the applicable statutes. ORS 91.855(2)3 applies to month to month tenancies and prescribes the following manner of giving notice of termination: the notice must be in writing, must designate a date of termination, and must be given not less than thirty days before the date of termination. Month to month tenancies are terminable upon thirty days’ notice by landlord or tenant for any reason or for no reason, except that a landlord may not retaliate as proscribed in ORS 91.865 and 91.870. The traditional purpose of such an arrangement is to allow either party to end the tenancy on relatively short notice without incurring additional liabilities. See McCall v. Fickes, 556 P2d 535, 539 (Alaska 1976) (construing a provision similar to ORS 91.855(2)). A landlord or tenant who prefers to have a tenancy for a longer term can bargain for such an agreement. ORS 91.740; 91.880(2) (parties may agree upon a specific term of the tenancy).

The landlord tenant act was amended to include statutes which apply only to rental agreements for mobile or floating home spaces. Or Laws 1975, ch 353; Or Laws 1977, ch 348. ORS 91.8854 applies to a [548]*548landlord’s termination, and, unlike ORS 91.855, does not permit termination for any or no reason. ORS 91.885 provides that the landlord may terminate the rental agreement if the tenant violates a law or ordinance which relates to the tenant’s conduct as a tenant, or violates a rule duly imposed as a condition of occupancy. ORS 91.885(2) requires that the notice set forth facts sufficient to notify the tenant of the reasons for termination, and 91.885(3) allows the tenant to avoid termination by correcting the violations within the thirty-day period. Thus the legislature has provided two termination procedures: ORS 91.855 which applies generally to month to month tenancies and ORS 91.885 which applies specifically to tenancies for a mobile home space.

The Court of Appeals in its opinion in this case stated that the landlord "elected” to proceed under ORS 91.885(1), rather than the simple 30-day notice provision in ORS 91.855(2). 43 Or App at 894. We read ORS 91.885 to be the exclusive method for a landlord to terminate a tenancy for a mobile home space. Our examination of the legislative history confirms this reading. Termination of a rental agreement for a mobile home space can involve a substantial expense and inconvenience to the tenant who must locate a new rental space and arrange for the moving [549]*549of the mobile home.

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Cite This Page — Counsel Stack

Bluebook (online)
615 P.2d 327, 289 Or. 543, 1980 Ore. LEXIS 1060, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ostlund-v-hendricks-or-1980.