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Lindsey v. Normet

Supreme Court of the United States · 1972 · Civil Procedure

Civil ProcedureConstitutional LawPropertyEvictionDue ProcessEqual ProtectionLandlord-Tenantforcible entry and detainer

Facts

Appellants were month-to-month tenants renting a Portland house from appellee for $100 per month. After the city declared the dwelling unfit for habitation because of substandard conditions, the tenants asked for repairs; appellee largely refused. The tenants paid November rent but withheld December rent until repairs were made, and before Oregon eviction proceedings began they sued in federal court challenging Oregon's FED statute on its face. They specifically attacked the statute's rapid trial schedule, its limitation of issues in possession actions, and its double-rent appeal bond requirement.

Issue

Whether Oregon's statutory eviction procedures for nonpayment of rent violated the Due Process Clause or Equal Protection Clause of the Fourteenth Amendment. More specifically, the Court considered the constitutionality of the early-trial provision, the limitation of issues in the FED action, and the double-bond prerequisite to appeal.

Rule

A state may constitutionally provide a prompt, peaceful, and limited possessory action between landlord and tenant, including early trial and issue restrictions, so long as the procedure affords a fair opportunity to litigate the possession issues and other claims may be brought separately. Under equal protection, classifications in this context are valid if rationally related to a legitimate state objective, but once a state affords appeals it may not arbitrarily impose burdens on a class of appellants that bear no reasonable relationship to a valid state purpose.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Columbus, Ohio, Pine Terrace Properties files a summary possession action against tenant Elena Park for failing to pay two months' rent. Ohio law requires trial within five days after service, but allows a longer continuance if the tenant posts security for rent that accrues during the delay if the landlord ultimately wins.

Elena brings a facial due process challenge, arguing that five days is always too short to prepare for trial. How should a court rule?

Explanation. The majority upheld a short trial schedule against a facial due process attack where the typical possession issues are simple and the tenant generally knows the relevant facts, such as payment, possession, lease terms, and notice. It also emphasized that a longer continuance conditioned on security for accruing rent is not irrational or oppressive. The Court did not hold that every application of a short schedule is valid, only that such a statute is not facially unconstitutional on that showing.