Supreme Court of New Hampshire
Jacqueline Lane v. Antonio Barletta
November 22, 2019
Summary
The Supreme Court vacated the trial court’s finding that the landlord willfully interrupted the tenant’s heat and the $66,000 damages award, holding that a landlord’s willful failure to repair after notice constitutes a statutory violation but remanding to determine whether the space heater provided was an adequate alternative source of heat; it also reiterated that enhanced damages under RSA 358-A:10 require a willful or knowing violation. The court noted the plaintiff’s motion for reconsideration was moot after vacating the judgment.