How does a Minnesota landlord lawfully end a tenancy, and when may a tenant leave early?

Landlord: 30 days. Tenant: 30 days.

Minnesota does not count days at all; it counts rent intervals. The written notice must run at least as long as the gap between rent payments, so a tenancy where rent falls due monthly takes a month, one where rent falls due weekly takes a week, and one where rent falls due every six months takes three months rather than six. For a monthly tenancy that is one month, which the statute states as a rent interval rather than as 30 days. The period runs forward from the written notice as a duration, and the statute says nothing about where in the month the tenancy has to end, so it neither requires nor forbids a termination date falling on a rent day.

Whether the termination date must fall on a rental-period boundary or a rent-due date differs between tenancy types or is not settled by the statute; the rule for each is stated above.

Tiers: One tier sits outside the rent-interval rule and it follows a foreclosure. Where the occupant was a tenant during the redemption period under a lease of any duration that began after the mortgage was executed, the person who takes the property must give at least 90 days' written notice to vacate, given no sooner than the day the redemption period expires and effective no sooner than 90 days after it, provided the tenant pays the rent and keeps to the lease. Where a genuine lease still has more than 90 days to run past redemption, the new owner must let the tenant stay to the end of the lease term and then give the 90 days, unless the new owner or a later genuine purchaser will live in the unit as a primary residence, in which case the 90 days may start sooner.

Ceiling on the notice a lease may require: Three months is the outer limit. However long the interval between rent payments, the notice period is the shorter of that interval and three months, so a lease with a six-month or annual rent interval still ends on three months' notice. Most secondary summaries state this backwards and treat three months as a longer period a Minnesota tenancy might need.

Only a longer period may be agreed. The statutory period is a floor, so a lease may set a longer one but not a shorter. What a lease may not do is set different periods for the two sides without consequence. Where a residential lease gives the landlord a period for a notice to quit or a rent increase that differs from the period the tenant must give to quit, the tenant may use either of the two, and the landlord may not give a notice to quit or of a rent increase shorter than the period the lease sets for the tenant. Those requirements may not be waived or modified by the parties, and any provision that tries is against public policy and void.

A statute requires the landlord's and tenant's periods to be equal, or bars a lease from imposing a longer period on one side.

Source of the period: a termination-notice statute states it.

Either party may end a tenancy at will by written notice, and the notice must run at least as long as the interval between rent payments or three months, whichever is less. That single sentence is the whole of Minnesota's periodic-notice statute: there is no 30-day figure anywhere in it, no separate landlord and tenant periods, and no requirement that the tenancy end on a rent day. A second section polices what a lease does with these periods, and it is unusually strong. It applies wherever a residential lease gives the landlord a period for a notice to quit or a notice of a rent increase that differs from the period it requires of the tenant, and it counts a notice of non-renewal as a notice to quit. The tenant may then choose either period, and the landlord may not use one shorter than the tenant's. None of that may be waived or modified, and a lease term that tries is void. A tenant who does not know the landlord's name and address, because they were not given in the rental agreement and not posted on the premises as the law requires, may give the notice to a caretaker, a manager, or the person to whom the rent is paid, each of whom is then a deemed agent for receiving notices and demands.

No: no statewide rule requires a reason, and no statute expressly authorizes local ordinances.

Local ordinances: no statute or decision addresses them. No Minnesota statute preempts a local just-cause or eviction-grounds ordinance and none authorizes one; the landlord-tenant chapter says nothing about local measures in either direction. The one Minnesota preemption statute in this area is about rent rather than grounds: no statutory or home rule charter city, county or town may adopt or renew a law controlling rents on private residential property, unless the measure is approved at a general election, and the bar does not touch a local government's power to manage property it has an interest in, to contract with an owner, to act as federal or state law requires, or to mediate between owners and tenants. That posture, and the ordinances that run through the general-election exception, are carried on the rent-increase page.

No reason is required to end a tenancy at will or to decline to renew a lease in Minnesota. There is no good-cause statute, no list of no-fault grounds and no relocation payment. Three narrower limits apply instead. A tenant may not be evicted, denied a continuing tenancy or denied a renewal because of a familial status that began during the tenancy, unless a year has passed since it began and the landlord has given six months' written notice, and none of that applies to non-payment of rent, damage, disturbance of other tenants or another breach of the lease; the protection may not be waived. In federally subsidized housing the landlord must give a year's written notice where a rental assistance contract will expire, where the landlord will end or decline to renew such a contract, where the landlord will prepay a mortgage in a way that ends federal use restrictions, or where the landlord will end a subsidy program, and the state's own published note records that the prepayment branch has been held preempted so far as it sets a longer timeline than federal law. And a landlord may not begin an eviction solely because the tenant or an authorized occupant has been a victim of the acts that support a victim's early termination, nor against a tenant who has ended a lease that way. Separately, no eviction action lies at all where the lease ended more than three years earlier and the occupant has had three consecutive years of quiet possession.

The term ends on its date; no statute requires notice from either side.

After the term, a statute supplies what a holdover becomes. The conversion statute works as a ceiling on what may be implied rather than as an affirmative rule. Where a tenant of urban real estate holds over and keeps possession after the lease expires without the landlord's express agreement, no tenancy may be implied for any period longer than the shortest interval between rent payments under the expired lease. So a tenant who paid weekly under the old lease cannot be held to an implied month, and a tenant who paid monthly cannot be held to an implied year. The section is limited on its face to urban real estate; for property outside that description Minnesota has no statute, and the implied-tenancy question is left to the general law.

Automatic-renewal reminder (15 days before): To enforce an automatic-renewal clause in a lease with an original term of two months or more that renews for a further two months or more unless the tenant gives notice, the landlord must send a written reminder that directs the tenant's attention to the automatic-renewal provision. It must be served personally or mailed by certified mail, and the timing is a window rather than a minimum: at least 15 days but not more than 30 days before the date the tenant would have to give notice of an intention to leave. A landlord who sends it too early fails as surely as one who sends it too late, and without a proper reminder the automatic-renewal clause cannot be enforced.

A Minnesota fixed term ends on its own date and no statute requires either side to give notice of non-renewal. Where the lease itself sets notice periods, the symmetry statute polices them: a notice of non-renewal counts as a notice to quit, so the landlord's period may not be shorter than the tenant's and the tenant may use either. Three further rules bear on the end of a term. A landlord may not require a tenant to renew sooner than six months before the current lease expires where the lease runs longer than ten months, and that may not be waived. A written lease must state its start date and its end date, and where the tenant is required to move in or out on a day other than the first or last of the month with rent prorated, it must state the prorated amount, all of it on the first page. And an automatic-renewal clause is unenforceable without the reminder described above.

A Minnesota holdover on urban real estate becomes, at most, a periodic tenant on the shortest rent interval of the expired lease, and only by implication where the landlord has not expressly agreed to anything. Holding over after the lease ends, or after a proper notice to quit expires, is also a ground on which the landlord may bring an eviction action, and that court process is on the eviction page.

Damages: No statutory enhancement: the landlord recovers ordinary rent or use and occupancy.

Minnesota attaches no statutory penalty to holding over. There is no double rent, no holdover rent and no multiplier of any kind in the landlord-tenant chapter; the landlord recovers the rent or the reasonable value of the occupation and pursues possession. The multiplied damages the chapter does contain all run the other way, against a landlord: for failing to disclose non-optional fees, for an unlawful exclusion or a wilful cut-off of services, and for interfering with a tenant's possession.

What a consented holdover becomes: The implied tenancy takes the shortest rent interval of the expired lease, and the section that says so applies only to urban real estate. Outside that description no Minnesota statute says what a holdover becomes.

No duty: the only appellate authority arises from commercial leases.

When it attaches: Nothing happens automatically when the tenant leaves. The duty attaches only when the landlord, by some act or statement, indicates acceptance of the tenant's abandonment and so in effect terminates the lease. Until that moment the landlord may leave the unit empty and sue for each installment of rent as it comes due. Once the landlord has terminated, the remedy becomes damages for the breach with the attendant obligation to use reasonable efforts to mitigate them from that point on.

The standard: Where the landlord has accepted the surrender and terminated, the standard is reasonable efforts to mitigate the damages arising after the breach; the Minnesota courts have not elaborated it further for a residential tenancy. Where the landlord has not, there is no standard to meet: the landlord may refuse a replacement tenant, wait, and recover the full rentals as they fall due, and the departing tenant gets no credit for savings the landlord makes as a result of the departure. No Minnesota decision says who must prove that efforts were or were not reasonable.

A lease clause accelerating all remaining rent is enforceable only with an offset for re-letting or another limit.

Whether a lease may waive the duty is not settled.

Minnesota is one of the states where the landlord need not re-let, and this is the rule most often stated backwards. The Supreme Court of Minnesota held in 1956 that a landlord does not have the duty of mitigating damages, may arbitrarily refuse a suitable and otherwise responsible subtenant, and may recover the full rentals due under the lease as and when they fall due, and said in terms that it adhered to that rule. It repeated the point in 1973, saying that in Minnesota landlords are under no obligation to mitigate damages after a tenant abandons leased premises, and adding that a tenant who abandons has no right to a reduction in rent for savings that accrue to the landlord. In 1975 it applied the rule again, holding that a tenant's unilateral abandonment, unless accepted by the landlord, does not terminate the lease, forfeit the estate or end the obligation to pay rent. The exception the 1956 decision drew is the whole of the other side: where the landlord by some act or statement has indicated acceptance of the abandonment and so terminated the lease, the remedy is damages for the breach with the attendant obligation to use reasonable efforts to mitigate them afterwards. A 2023 published Court of Appeals decision applies that branch and adds the practical limit on lease drafting: a liquidated-damages clause is unenforceable where the actual damages are capable of accurate estimation and the clause does not account for the landlord's duty to mitigate, so an acceleration or liquidated sum that ignores re-letting will not stand. Every decision in the line arose from a commercial lease, though the no-duty holding is a general statement of Minnesota law.

No statute addresses a fee a landlord may charge for ending a lease early; the general damages rules govern.

No Minnesota statute authorizes, caps or bars a fee for ending a residential lease early, and none caps the damages a landlord may recover after an early departure. Two things constrain such a charge instead. The first is judicial: a liquidated-damages clause is unenforceable where the actual damages caused by the breach can be estimated accurately and the amount fixed does not account for the landlord's duty to mitigate, so a buy-out sum that ignores re-letting is at risk. The second is the fee-disclosure statute: every non-optional fee must be disclosed in the lease, and the sum of the rent and all non-optional fees must be described as the Total Monthly Payment and appear on the first page of the lease, with treble damages and attorney fees against a landlord who does not comply. Minnesota's administrative rules were read for a fee rule and none exists: the only agency plausibly regulating residential leases is the housing finance agency, whose rules chapter was enumerated part by part and covers loans, grants and program administration alone.

Early-exit rights by ground: domestic violence and related grounds, a statutory right to end the lease; military service beyond the federal act, state orders or National Guard duty are covered; death of the tenant, a statutory route; and other statutory grounds.

Domestic violence and related grounds: a victim may end the lease on notice.

Who qualifies: A tenant on a residential lease where the tenant, or another authorized occupant, fears imminent violence after being subjected to domestic abuse as the Domestic Abuse Act defines it, criminal sexual conduct, sexual extortion, or harassment as the criminal code defines those. The test is a present fear of imminent violence rather than a particular relationship to the person responsible, and the fear may be the tenant's own or attach to an authorized occupant. Human trafficking is not one of the named grounds; a trafficking victim reaches the section only where the conduct also falls inside one of the four listed offenses.

Documentation: The notice must be accompanied by a qualifying document, and the list is closed at five. A valid order for protection; a no-contact order currently in effect; a signed writing from a court official documenting that the tenant or an authorized occupant was a victim and naming the person responsible if known, a court official here meaning a judge, referee, court administrator, prosecutor, probation officer or victim's advocate whether employed by or under contract with the court; the same kind of signed writing from a city, county, state or tribal law-enforcement official; or the statement whose form the statute sets out, signed by a qualified third party. A qualified third party is someone acting in an official capacity who has provided professional services to the tenant and is a licensed health care professional, a domestic abuse advocate, or a sexual assault counselor. The notice and the documentation go to the landlord together.

Window: Minnesota states no window at all, and the absence is deliberate rather than a gap. There is no look-back limiting how recently the violence must have happened and no deadline by which the tenant must act after it. What the statute asks is that the tenant fear imminent violence now, and that the qualifying document be a valid one, so an older order still in effect supports a termination today.

Notice: Minnesota states no period. The tenant gives signed and dated advance written notice that names the date the lease will end, and the tenancy, including the right of possession, ends on that date. The notice must also say that the tenant fears imminent violence from a person indicated in the qualifying document, say that the tenant needs to end the lease, and give written instructions for what to do with any personal property left behind. It may be delivered by mail, in person, or by whatever written channel the tenant regularly uses to communicate with the landlord, and the qualifying document goes with it. Leaving the unit before the date named does not itself end the tenancy.

Rent owed: The tenant owes the rent for the whole month in which the tenancy ends, and nothing beyond it: all other contractual obligations to pay rent or other charges for the remaining term fall away. Rent and other amounts already owed before the termination survive it.

Cost to the tenant: There is no fee or penalty for using the right, but there is a price that must be read with it: the tenant relinquishes all claims for the return of the security deposit. Together with the full month's rent, that is what a Minnesota victim termination costs. In a shared tenancy every tenant loses the deposit claim, not only the one who gave notice.

Other tenants on the lease: the victim's termination ends the lease for everyone on it. Minnesota is the opposite of most states here. Where there are several tenants and one of them ends the lease this way, any lease governing all the remaining tenants ends too, at the later of the end of the month or the end of the rent interval in which that tenant terminates. Everyone is responsible for the rent for that full month, everyone relinquishes their claim to the security deposit, and any tenant whose tenancy ends this way may apply to the landlord for a new lease.

Locks: Lock changes are not addressed.

Later screening: more than one form of protection. Two protections operate, and together they are stronger than a plain screening rule. The first bars the landlord from disclosing anything the tenant put in the notice, anything in the qualifying document, the address or location the tenant has moved to, or the tenant's status as a victim of violence, and bars any of it being entered into a shared database or given to any person or entity; it may be used only as evidence in an eviction case, in an action for unpaid rent or damages from the tenancy, in a deposit claim, with the tenant's consent, or where the law otherwise requires. That duty is paramount and overrides any release-of-information form the tenant signed earlier, and a landlord who breaks it owes the tenant statutory damages of two thousand dollars plus fees and costs. The second bars the landlord from beginning an eviction solely because the tenant or an authorized occupant was a victim of the acts the section covers, or against a tenant who has ended a lease under it, and shifts the cost of getting the court record expunged onto a landlord who does.

The landlord must keep the victim's documentation or status confidential.

Deadline to move out: The tenant must actually be out on or before the date named in the notice. A tenant who gives the notice and then fails to leave by that date is outside the protection against eviction, and the landlord may bring an eviction action on that footing. Leaving early does not bring the termination date forward.

The landlord's side: The landlord may ask the tenant to name the person responsible, and if the landlord asks, must tell the tenant that the reason is to protect other tenants in the building. The tenant may decline, and disclosure may not be made a precondition of ending the lease. Against that, the landlord may not begin an eviction against a tenant who has terminated under the section, except where the tenant has broken the lease or gave the notice and then did not leave on time. Where a federal statute, regulation or handbook governing a subsidized tenancy conflicts with the section, the landlord must follow the federal rule. The tenant's rights under the section cannot be waived, and a landlord may not require a waiver.

A tenant who fears imminent violence after being subjected to domestic abuse, criminal sexual conduct, sexual extortion or harassment, or whose authorized occupant does, may end the lease without penalty or liability. The tenant gives signed and dated advance written notice naming the date the lease will end, stating the fear and the need to leave and giving instructions for any property left behind, and encloses one of five qualifying documents: an order for protection, a current no-contact order, a signed writing from a court official or from a law-enforcement official, or the statutory statement from a qualified third party. Minnesota sets no notice period and no window tied to the incident; the tenant names the date and the tenancy ends then. Rent is owed for the whole month in which it ends, and the tenant gives up any claim to the security deposit. Where several tenants share the lease, the lease ends for all of them, all of them lose the deposit claim, and any of them may apply for a new lease. The landlord must keep the notice, the document, the tenant's new address and the tenant's victim status confidential, may not put any of it into a shared database, and owes two thousand dollars plus fees for breaking that duty.

Military service: State orders or National Guard duty are covered.

When the state rights attach: The extension attaches to a person called or ordered to state active service, which excludes federal active service and covers duty on behalf of the state in a disaster, war, riot or breach of the peace or in aid of civil authority, duty at encampments ordered by state authority, other duty ordered or requested by state authority that takes the person's time, and travel to and from any of those; and to federally funded state active service, meaning duty under Title 32 of the United States Code and travel to and from it. There is no minimum length of orders and no separate state notice period, because the section grants the federal protections rather than writing new ones. Its reference to the federal act is written to carry forward as that act is amended.

Minnesota's landlord-tenant chapter says nothing about the military, but the Military Code does. A person called or ordered to state active service, or to federally funded state active service under Title 32, has all the protections the federal Servicemembers Civil Relief Act gives to persons in the military service of the United States, as that act stands from time to time, together with the federal reemployment rights act. Because the grant takes in the whole federal act, the residential lease-termination right travels with it, and a National Guard member on state duty that federal law would not itself cover may end a lease on the federal terms. Minnesota adds no shorter threshold, no independent right for a spouse or dependents and no faster effective date.

Death of the tenant: A statute provides for ending the lease on the tenant's death. Minnesota lets either side end the lease when the tenant dies. On the death of the tenant, or where there is more than one tenant on the death of all of them, either the landlord or the personal representative of the tenant's estate may end any residential lease other than a lease at will before its expiry date. The notice must be written, must give at least two months, and must be effective on the last day of a calendar month; it is hand-delivered or sent by first-class prepaid post to the other party's address, and a landlord may address it to the premises the tenant used to occupy. Ending the lease does not release the estate from rent and other sums owed before or during the notice period, nor from the cost of putting the premises back into the condition they were in at the start of the tenancy, ordinary wear and tear excepted. Any attempt to waive the section, and any lease term requiring a longer notice period than it gives, is void, though the landlord and the personal representative may agree to modify it otherwise. The section reaches leases entered into or renewed after May 12, 1981.

Other grounds: Minnesota has one further statutory exit, and it is a strong one. A tenant, or the tenant's authorized representative, may end the lease early where a medical professional has found that the tenant, or one of several tenants, needs to move into a medical care facility and either requires assistance with daily living activities for medical reasons or a disability, meets one of the nursing-facility level-of-care criteria, or has a disability or functional impairment in three or more of the statutory areas so that self-sufficiency is markedly reduced because of a mental illness. A medical professional here means a licensed physician, an advanced practice registered nurse or a mental health professional, and a medical care facility is a defined list of ten: a nursing home, hospice care, a residential hospice facility, a boarding care home, a supervised living facility, assisted living, an accessible unit, a state facility, adult foster care and intensive residential treatment. The notice is written, gives at least two months and takes effect on the last day of a calendar month, is hand-delivered or sent by first-class prepaid post, and must enclose both the professional's written documentation and proof that the tenant has been accepted at the facility or has an application pending where the professional says the move is needed. Rent and restoration liability run through the notice period. There is one carve-out that matters: where the tenant needs an accessible unit and the landlord can provide one in the same complex within two months of the request, the section does not apply and the tenant may not use it. The right cannot be waived and a longer lease-set notice period is void. Minnesota has no job-relocation ground, no casualty or destruction termination and no landlord-harassment termination. Ending a lease because the landlord has not kept the unit habitable is on the habitability page.

No statute treats absence as ending the tenancy; the common law governs.

Minnesota has no abandonment presumption and no notice-of-belief procedure. No statute says that an absence of any length ends a tenancy, and no statute gives the tenant a window to answer a landlord who believes the unit has been abandoned. The one section that uses the word takes abandonment as a fact and then regulates only what the landlord must do with the property left behind: take possession of it, store it and care for it, with a claim against the tenant for the reasonable cost of removing and storing it, and a power to sell or otherwise dispose of it 28 days after the landlord receives actual notice of the abandonment or 28 days after it reasonably appears that the tenant has abandoned, whichever is later. Before a sale the landlord must make reasonable efforts to tell the tenant at least 14 days ahead, by personal service or by both first-class and certified post to the tenant's last known address, and must post notice of the sale conspicuously on the premises for at least two weeks. Whether the tenancy itself has ended is a question the statutes leave to the courts, and the answer is that it has not: a tenant's unilateral abandonment does not end the lease unless the landlord accepts it, so the rent obligation continues until the landlord terminates. What the landlord may finally do with the property is covered separately.

For an ordinary termination of a tenancy at will Minnesota requires writing and nothing else. There is no prescribed delivery method, no order of preference, no certified-mail rule and no proof-of-service rule, so how the notice travels is left to the parties. Particular notices do carry their own methods and they differ from one another: the automatic-renewal reminder must be served personally or by certified mail, the death-of-tenant and infirmity notices must be hand-delivered or sent by first-class prepaid post and take effect on the last day of a calendar month, and a victim's termination notice may go by post, in person, or by whatever written channel the tenant regularly uses with the landlord.

Electronic delivery: the termination statute is silent on it.

What the notice must contain: For an ordinary termination the only requirement is that the notice be in writing. Nothing has to be recited, no ground has to be given and no form is prescribed. The specialized notices are different: a victim's termination notice has a four-part content list, and an infirmity notice must enclose the medical documentation together with proof of acceptance at a facility or of a pending application.

Alternate address: The address a tenant sends a notice to is itself regulated. A landlord must disclose the landlord's name and address, or an authorized agent's, in the rental agreement or otherwise in writing before the tenancy begins, and must post it conspicuously on the premises. Where that has not been done and the person giving the notice does not know the name and address, a caretaker or manager of the premises, or the person to whom the rent is paid, is a deemed agent authorized to accept service and to receive and give receipt for notices and demands on the landlord's behalf.

Minnesota's landlord-tenant chapter defers to federal law in two places and has been cut back by it in a third. The victim-termination section says that where a federal statute, regulation or handbook permitting termination of a federally subsidized tenancy conflicts with the section, the landlord must follow the federal rule. The subsidized-housing notice section carries the state's own published note recording that one of its branches has been held preempted so far as it sets a longer termination timeline than federal law. And the eviction chapter writes a 90-day post-foreclosure notice to vacate into state law, along with the rule that a genuine lease running past redemption must be allowed to expire.

The federal CARES Act 30-day notice to vacate for covered properties, as read in this state's courts: no state appellate decision construes it. No Minnesota appellate decision construes the federal 30-day notice for covered dwellings, and the landlord-tenant chapter does not write it into state law: neither the Supreme Court of Minnesota nor the Court of Appeals has published a decision that reads the provision. The federal provision is unrepealed and unamended and applies of its own force to covered dwellings, so a landlord of a covered dwelling whose own notice would be shorter should treat the 30 days as governing; how a Minnesota court would read its scope is an open question. (Appellate picture read as of September 4, 2026.)

Gruman v. Investors Diversified Services, Inc., 247 Minn. 502, 78 N.W.2d 377 (Supreme Court of Minnesota, 1956; arose from a commercial lease; bears on the duty to re-let): Surveying the split among the states, the court held that a landlord under a lease of this kind does not have the duty of mitigating damages, may arbitrarily refuse to accept a subtenant who is suitable and otherwise responsible, and may recover from the tenant the full rentals due under the lease as and when they fall due, and said in terms that it adhered to that majority rule. It drew the exception that still governs: where a landlord by some act or statement has indicated acceptance of the tenant's abandonment and so in effect terminated the lease, the remedy is damages for the breach with the attendant obligation to use reasonable efforts to mitigate those damages afterwards. The case arose from a commercial lease and turned on a sublease-and-assignment clause.

Control Data Corp. v. Metro Office Parks Co., 296 Minn. 302, 208 N.W.2d 738 (Supreme Court of Minnesota, 1973; arose from a commercial lease; bears on the duty to re-let): The court restated the rule in a single sentence: in Minnesota landlords are under no obligation to mitigate damages after a tenant abandons leased premises. It added that a tenant who abandons leased premises has no right to a reduction in rent for savings that accrue to the landlord as a result of the abandonment. The dispute concerned commercial office space, and the statement is a general one about Minnesota landlord-tenant law.

Markoe v. Naiditch & Sons, 303 Minn. 6, 226 N.W.2d 289 (Supreme Court of Minnesota, 1975; arose from a commercial lease; bears on the duty to re-let): A tenant's unilateral act in abandoning leased premises, unless the landlord accepts it, does not terminate the lease, forfeit the estate granted by it, or end the tenant's right to use and possess the premises and the matching obligation to pay the rent due for them. Finding no evidence that the landlord had accepted the abandonment, and no obligation in Minnesota to mitigate after a tenant abandons, the court upheld the judgment for the rent. The lease was commercial.

Lagoon Partners, LLC v. Silver Cinemas Acquisition Co., No. A23-0194 (Minn. Ct. App. Dec. 11, 2023) (Minnesota Court of Appeals; arose from a commercial lease; bears on the duty to re-let): The liquidated-damages clause in the parties' lease was unenforceable because the actual damages caused by the tenant's breach could be estimated accurately and because the sum fixed, which did not account for the landlord's duty to mitigate damages, was not a reasonable forecast of the actual damages. The decision applies the branch of Minnesota law on which a duty to mitigate does arise, namely where the landlord has terminated the lease after a breach; it does not create a general duty. The lease was a commercial one, of a Minneapolis theater.