Geldhof v. Penwood Associates

The issue in this case is whether RSA 477:48 (Supp. 1977), which requires landlords to pay interest on security deposits, affects deposits tendered under lease agreements executed prior to the effective date of the statute. We hold that it does not.

Mr. and Mrs. Joseph Geldhof rented an apartment from Penwood Associates, Inc., on September 11,1976. The parties executed a lease under which the tenant gave the landlord $140 as a security deposit. The lease did not mention interest. On September 13, 1977, the legislature enacted RSA 477:48 (Supp. 1977). Eight months later the parties terminated…