Geldhof v. Penwood Associates, 119 N.H. 754 (1979)

Citation: Geldhof v. Penwood Associates, 119 N.H. 754 (1979)
Parent Document: Geldhof v. Penwood Associates, 119 N.H. 754 (1979)
Jurisdiction: New Hampshire (state)
Effective Date: 1979-10-12
Original Source: https://www.courtlistener.com/opinion/1911108/geldhof-v-penwood-associates/ ↗

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The lease in question in this case, signed in 1976, created a one-year term which was automatically renewed in the absence of a termination notice. Because the tenancy continued, Penwood had no duty to calculate and pay interest on the Geldhofs’ security deposit. To impose such a duty prior to the expiration of the tenancy would be to create “a new obligation ... in respect to [a] transaction ... already past.” Under our constitution, no such retrospective duty may be imposed.

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