Minnesota Court of Appeals Rules Lockout of an Uninhabitable Property Unlawful
On June 16, 2025, the Minnesota Court of Appeals issued a precedential decision in Murphy v. Aeon, A24-1159, and held that a when a unit is deemed uninhabitable by a city, the tenant must be provided due process before a landlord can lockout the tenant.
In Murphy, there was a fire in the unit next-door to the tenant. The City of New Hope determined the tenant's apartment was temporarily uninhabitable due to the fire. The tenant returned to obtain his belonging, but the landlord had padlocked the door.
Key Takeaways from the Decision:
Self-Help Lockouts Are Unlawful — Even Temporarily
The Minnesota Court of Appeals reaffirmed the long-standing law that a landlord may not result to self-help exclusion or removal of a residential tenant. Self-help evictions are removals of a tenant without resort to judicial eviction proceedings, and includes terminations of utilities or removal of doors, windows, or locks.
The Minnesota Court of Appeals once again concluded that any exclusion of a tenant from a leased property, without judicial process, is a violation of law. Even a temporary padlock that prevents access — not just occupancy — is considered an unlawful lockout.
City Orders Do Not Override Tenant Possession Rights
Of particular importance, the Minnesota Court of Appeals rejected the argument that a landlord may resort to a self-help eviction when a city determines the leased property is uninhabitable. While a city may bar occupancy of a leased property, that does not extinguish the tenant's legal right to possession. The landlord could not preclude the tenant's possession of or access to the leased property without resorting to court involvement.
Damages Go Beyond Rent Abatement
Even when the fire was not caused by the landlord, the tenant was entitled to seek alternative housing costs and consequential damages in a tenant remedies action when the landlord was unable to provide a safe and habitable home due to the fire.
Why This Case Matters
For tenants, the ruling is a powerful affirmation of the right to access their home and belongings — even after disaster strikes. For landlords, it’s a cautionary tale: regardless of city orders, due process must be followed before barring a tenant from their rental unit.
