Efficiency Lodge, Inc. v. Neason

Summary

We need to summarize this caselaw for search indexing. Key legal topics: landlord-tenant relationship, innkeeper-guest relationship, eviction, dispossessory proceedings, extended-stay motel, possession

Holdings

1. A landlord-tenant relationship is created when the owner grants the right to possess and enjoy the property, which may be express or implied. Possession is established by acts of ownership and control, including using property as a dwelling place. Consent is determined from the written agreement and, if necessary, the parties' conduct. The lower courts erred by not applying this framework and by treating the landlord-tenant and innkeeper-guest inquiries as strictly interchangeable.

Questions Presented

1. Whether an extended-stay motel must go through dispossessory proceedings to evict occupants who have stayed there for a long period of time, i.e., whether the parties are in a landlord-tenant relationship.

Disposition

vacated