Dinh v. Raines
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In this case, tenants Matthew Raines and Melissa Clayton complained to their landlord, Tuyen Dinh, about the habitability of their rented unit, particularly due to issues with their utilities and the presence of unauthorized tenants in the building. The tenants withheld rent and requested reimbursement for additional utilities costs. When Dinh refused and subsequently evicted the tenants for nonpayment of rent, a dispute ensued. The Superior Court of the State of Alaska held a damages trial, finding largely in favor of the tenants.
The Supreme Court of the State of Alaska affirmed the lower court's findings that Dinh failed to maintain the premises in a habitable condition and willfully diminished the tenants' essential services under the Uniform Residential Landlord and Tenant Act (URLTA). However, the Supreme Court reversed the lower court's conclusion that the tenants could recover for the landlord's failure to deliver possession of the property. The Supreme Court also affirmed some aspects of the lower court's award of damages, but reversed those awards that were not supported by the record.
The court found that Dinh's violation of housing codes and his conditional use permit diminished the value of the tenants' leasehold by the $8,800 owed in past rent. The court also found that Dinh was responsible for additional costs incurred by the tenants due to the unauthorized use of their utilities by unauthorized tenants in the building. However, the court ruled that the tenants could not recover for Dinh's failure to deliver possession of the property, despite finding that Dinh did not deliver habitable premises at the commencement of the lease.
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