Olentangy Commons Owner, L.L.C. v. Fawley

Citations

• 228 N.E.3d 621
• 2023 Ohio 4039

Syllabus

Although appeal of the forcible entry and detainer action became moot when appellant vacated the apartment, appellant established that the exception to the mootness doctrine for cases of great public or general interest applied to the case because the issue raised in the appeal impacts substantial numbers of landlords, tenants, and property managers. The unambiguous language of 15 U.S.C. 9058(c)(1) requires a lessor of a covered dwelling to provide a tenant with a notice to vacate 30 days before filing a forcible entry and detainer action. A municipal court possesses subject-matter jurisdiction over forcible entry and detainer actions, but will lack jurisdiction over a particular forcible entry and detainer action if the plaintiff fails to provide a 30-day notice to vacate if required by 15 U.S.C. 9058(c)(1).