Lyle v. Mangar, 36 A.3d 867 (2011)

Citation: Lyle v. Mangar, 36 A.3d 867 (2011)
Parent Document: Lyle v. Mangar, 36 A.3d 867 (2011)
Jurisdiction: Maine (state)
Effective Date: 2011-12-15
Original Source: https://www.courtlistener.com/opinion/5144930/lyle-v-mangar/ ↗

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. Even if we were to treat the statute's silence as creating an ambiguity, see Anastos v. Town of Brunswick, 2011 ME 41, ¶ 9, 15 A.3d 1279, the legislative history of the statute demonstrates a limited purpose to provide an orderly process for the return of a security deposit. See L.D. 1813, Statement of Fact (108th Leg-is.1977) (stating that the bill "provides for an orderly procedure for the refund of these deposits”); see also 2 Legis. Rec. 1372-73, 1655 (1977) (discussing the purpose of preventing landlords from retaining tenants’ security deposits without explanation or justification). Nothing in the legislative history suggests an intention to prevent a landlord's claim for breach of a rental agreement from proceeding *872while the security deposit remains in the landlord’s possession.

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