Schwartz v. McAtee

The question in this case is whether a manufactured home park operator can successfully maintain an action in forcible entry and detainer against a tenant who has neither defaulted in payments of rent nor breached the terms of his rental agreement.

I

Mobile homes are a twentieth century creation, but today’s manufactured homes bear little resemblance to yesterday’s trailers. “Mobile” Homes? — Public and Private Controls (1982), 29 Wayne L. Rev. 177, 180. The first trailers were without toilet or bathing facilities and could be pulled by passenger cars. Id. at 178-181. Over the years, the…