Sims v. Century Kiest Apartments

567 S.W.2d 526, 1978 Tex. App. LEXIS 3404
CourtCourt of Appeals of Texas
DecidedMay 5, 1978
Docket19368
StatusPublished
Cited by17 cases

This text of 567 S.W.2d 526 (Sims v. Century Kiest Apartments) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sims v. Century Kiest Apartments, 567 S.W.2d 526, 1978 Tex. App. LEXIS 3404 (Tex. Ct. App. 1978).

Opinions

GUITTARD, Chief Justice.

Willie Sims brought this suit against Century Kiest Apartments, his former landlord, for damages for a retaliatory eviction. The principal question is whether a former tenant has a cause of action for termination of his periodic tenancy and eviction by forcible detainer proceedings in retaliation for the tenant’s reporting of code violations to city authorities. We hold that such a cause of action, if established by evidence, does exist, and, consequently, that the trial court erred in rendering summary judgment for the landlord on the pleadings.

Sims alleged that he had been a tenant at. Century Kiest Apartments for approximately nine years under an oral tenancy from week to week; that during his occupancy the condition of the premises had steadily deteriorated; that he had repeatedly complained to the management about the problem and had helped organize a tenants’ council; that acting on his own and as officer of the council, he had reported to city authorities violations of various housing, building and health codes; that although his rent was fully paid, he had received from the landlord a written notice to vacate the apartment within ten days; that his tender of the full rent due on the next rent-payment date was refused; that the landlord had filed a forcible detainer suit [528]*528against him and recovered judgment for possession of the premises in the justice court and also, on appeal, in the county court at law; that the landlord’s termination of the tenancy was done with specific intent to retaliate against him for organizing and belonging to the tenants’ council, complaining to the management about needed repairs and maintenance, and reporting code violations to various departments of the city; and that as a result of the termination of the tenancy, he was injured by being forced to move out of his home and “has suffered a chilling effect of his exercise of his First Amendment rights.” He seeks recovery of his moving expenses, the additional rent he had to pay for a comparable apartment, damages for “deprivation of his First Amendment rights,” punitive damages, and his attorney’s fee.

The landlord filed a motion for summary judgment on the sole ground that plaintiff was a tenant from week to week, that the landlord had “an absolute right to terminate a tenancy at will when proper notice is given to the tenant of such termination,” and that it was undisputed that such a notice had been given. Although the motion was not accompanied by affidavits or any other summary-judgment proof, the tenant filed an opposing affidavit tending to support the allegations of his petition.

The landlord attempts to justify the summary judgment in its favor on the ground that it has an absolute right to terminate the tenancy on proper notice at the end of any week, and then to recover possession of the premises, and that its motive in doing so does not give rise to an action for damages. The tenant recognizes the rule that ordinarily a landlord may terminate a periodic tenancy without cause, but contends that if it does so for the purpose of interfering with the tenant in the exercise of his constitutional rights of free speech and free assembly, or in retaliation for his exercise of those rights, a legal wrong has been done for which an action for damages will lie.

We agree with the tenant that the petition is sufficient to state a cause of action for damages. Although no reported decision in Texas has dealt with the question, the legal consequences of a retaliatory eviction have been considered in a number of other jurisdictions. A crucial consideration is whether the tenant’s rights are infringed. The leading case holding that the tenant’s rights áre infringed is Edwards v. Habib, 130 U.S.App.D.C. 126, 397 F.2d 687 (1968), cert. denied, 393 U.S. 1016, 89 S.Ct. 618, 21 L.Ed.2d 560 (1969), in which the United States Court of Appeals for the District of Columbia Circuit allowed a defense of retaliation in a summary-possession proceeding on the ground that the policy of Congress in directing the promulgation of housing regulations in the District of Columbia for the benefit of tenants would be contravened by allowing evictions for reporting violations of such regulations. By resting its decision on the public policy implicit in the statute, the court avoided a decision based solely on constitutional grounds. Acknowledging that the summary-possession statute made no provision for such a defense, the court said:

“It is true that in making his affirmative case for possession, the landlord need only show that his tenant has been given the 30-day statutory notice, and he need not assign any reason for evicting a tenant who does not occupy the premises under a lease. But while the landlord may evict for any legal reason or for no reason at all, he is not, we hold, free to evict in retaliation for his tenant’s report of housing code violations to the authorities. As a matter of statutory construction and for reasons of public policy, such an eviction cannot be permitted.” [Id. 130 U.S.App.D.C. at 409, 397 F.2d at 699]

Concerning the practical effect of permitting eviction in retaliation for reporting code violations, the court observed:

“There can be no doubt that the slum dweller, even though his home be marred by housing code violations, will pause long before he complains of them if he fears eviction as a consequence. Hence an eviction under the circumstances of this case would not only punish appellant [529]*529for making a complaint which she had a constitutional right to make, a result which we would not impute to the will of Congress simply on the basis of an essentially procedural enactment, but also would stand as a warning to others that they dare not be so bold, a result which, from the authorization of the housing code, we think Congress affirmatively sought to avoid.” [Id. 130 U.S.App.D.C. at 412, 397 F.2d at 701]

This decision has been followed in a number of cases in the state courts.1

Relief against retaliatory eviction has also been granted in the federal courts. There, the main consideration has been whether “state action” was involved so as to provide a right of action under the Fourteenth Amendment of the United States Constitution and under the Civil Rights Act, 42 U.S.C. § 1983. In at least one case, it has been held that invocation of a state remedy for summary possession, such as our forcible detainer procedure, is in itself sufficient state action to establish a violation of federal constitutional rights if the landlord is motivated solely by retaliation against the tenant for reporting violations of housing regulations. Hosey v. Club Van Cortlandt, 299 F.Supp. 501, 506 (S.D.N.Y.1969). Other federal courts have required some kind of special state support of the landlord’s position other than merely providing a “neutral” remedy available to all landlords before state action has been recognized. McQueen v. Druker, 438 F.2d 781, 785 (1st Cir. 1971); LaVoie v. Bigwood, 457 F.2d 7 (1st Cir. 1972); Walton v. Darby Town Houses, Inc., 395 F.Supp. 553, 559 (E.D.Pa.1975).

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Sims v. Century Kiest Apartments
567 S.W.2d 526 (Court of Appeals of Texas, 1978)

Cite This Page — Counsel Stack

Bluebook (online)
567 S.W.2d 526, 1978 Tex. App. LEXIS 3404, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sims-v-century-kiest-apartments-texapp-1978.