Dobens v. Fagnant, 2025 N.H. 31 (2025)

Citation: Dobens v. Fagnant, 2025 N.H. 31 (2025)
Parent Document: Dobens v. Fagnant, 2025 N.H. 31 (2025)
Jurisdiction: New Hampshire (state)
Effective Date: 2025-07-17
Original Source: https://www.courtlistener.com/opinion/10634920/dobens-v-fagnant/ ↗

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[¶13] We now turn to the plaintiffs’ argument that the trial court erred in
finding that their holdover tenancy expired on October 15, 2022, and that they
were thus not entitled to 18 months’ notice. The parties do not dispute that
the plaintiffs’ occupancy of their unit at Hills Park was on a seasonal basis.
While their use and enjoyment of their unit was limited to the renting season,
the plaintiffs kept their manufactured housing unit on the site in Hills Park
throughout the year. Throughout the off-season, when the plaintiffs were not
occupying their unit but it nonetheless remained on the site, the plaintiffs were
tenants. See RSA 205-A:1, IV (2019) (“‘Tenant’ means any person who owns or
occupies manufactured housing and pays rent or other consideration to place
said manufactured housing in a manufactured housing park.”). Accordingly,
although the plaintiffs’ occupancy of the unit was only seasonal, they were
tenants throughout the entire year.

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