Resident Met $15,000 Threshold Needed for a Jury Trial

Facts: A resident rented a unit at a federally subsidized site for a number of years. In March 2013, the owner notified the resident that, because of numerous lease violations, it was terminating her lease effective April 12, 2013, and directed her to vacate the unit by that date.

The owner’s termination letter claimed that: (1) the unit was damaged by a fire when the stovetop was left on and unattended; (2) the resident hadn’t reimbursed the owner the $3,847.30 for that fire damage; (3) children “occupying” her unit “were lighting matches and allowing them to burn holes in the staircase to the common area”; (4) upon inspection of her unit, the owner discovered “broken blinds, broken door knobs, missing sprinkler covers, and buckling walls”; (5) other site residents had “submitted regular complaints of noise and heavy traffic of non-residents coming from” her unit; (6) “security and police have visited the property on reports of illegal activity, including use of marijuana”; (7) an “altercation involving a knife and a baton” occurred in her unit that “led to significant injury” to some of her guests and that one or more of them had been “sent to the hospital for bleeding from the head and abdomen”; and (8) on one occasion, there were “loud, verbal arguments” between her guests.

When the resident didn’t vacate, the owner filed a breach-of-lease action seeking repossession of the unit. The resident, in turn, demanded a jury trial, claiming that the amount in controversy exceeded $15,000, the threshold sum for such a proceeding. The owner then filed a motion to strike the resident’s jury demand, contending that the amount in controversy was, in fact, less than $15,000 and that, therefore, the district court had exclusive jurisdiction over the matter. The circuit court agreed and struck the resident’s demand for a jury trial. The resident appealed this decision.

Ruling: A Maryland appeals court ruled for the resident and reversed the circuit’s court decision.

Reasoning: The resident reasoned that, because her lease, by its express terms, automatically renews for successive one-year terms unless terminated for good cause, she has a right to possess the unit for an “indefinite period of time” and, thus, the value of her right to possess the premises should have been calculated by multiplying the annual fair market rental payment by the number of years of her remaining estimated life expectancy, the product of which exceeds $15,000.

The court agreed and rejected the approach advocated by the owner, which valued the resident’s right to possess the unit, not by multiplying her annual rent by her estimated life expectancy, but by multiplying her monthly rental payment by the number of months that remained on her current lease, which was due to expire on Dec. 31, 2013 (approximately nine months after the owner notified the resident that it was terminating the lease).

• Kirk v. Hilltop Apartments, September 2015