Reversal: Ministry’s re-entry program excepted from landlord-tenant statutes

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A South Bend ministry that provides transitional housing and job training for people re-entering society after incarceration won an appeal against a man who was awarded damages after claiming he was wrongly barred from the property and forced to come up with money to stay at a hotel.

The Indiana Court of Appeals remanded the case to the St. Joseph Superior small claims court, finding the ministry falls under an exception to Indiana’s landlord-tenant statutes.

The case began when DeParris Pratt came to live at a residence owned by Jason Pfledderer’s nonprofit, Walking With Jesus Ministries. The ministry provides shelter for participants who agree to conditions including attending church services, attending meetings that reflect on scripture and seeking full-time employment. Participants must pay a program fee of $100 per week.

Pratt signed no lease, paid no rent and spent about a month at the property, during which time he worked about 30 hours for Pfledderer but received no pay, according to the record. A footnote observed that Pfledderer said the painting, scrapping, cleaning, yard work and other chores Pratt performed was recorded on time sheets, but he was not compensated because “Pratt’s hours of work amounted to job training.”

In April of 2019, Pfledderer changed the locks on the property where Pratt had been staying, and Pratt was informed that Pfledderer wanted him to leave because he had broken program rules by smoking in and around the property, failing to obtain employment and failing to pay the weekly program fee. A few days later, Pratt filed a notice of claim and motion for emergency possession seeking damages based on lost personal property and other available relief.

After a couple of hearings, the small claims court acknowledged the statutory exception to the landlord-tenant rules for religious organizations but found the ministry failed to prove they applied in Pratt’s case. The small claims court found Pratt was wrongly ejected and that the ministry should have first gone to court. It found that Pratt’s property had been returned to him but awarded him $350, crediting his testimony that he had to spend $35 a day to rent a hotel room after he was barred from ministry housing.

The Court of Appeals reversed in Jason Pfledderer and Walking With Jesus Ministries v. DeParris Pratt, 19A-SC-1723.

The panel noted the legislative intent of the religious organization exception is to provide precisely the type of services the ministry sought to provide in this case. “Freeing such organizations from the strictures of the Landlord-Tenant Act will allow them to continue to help people who desperately need it — for example, people who are attempting the monumental task of reintegrating into society following incarceration,” Judge John Baker wrote. “We infer that the legislature determined that encouraging such services is in the best interest of the individuals who need the help as well as society at large.

“… The trial court found that because Pfledderer and/or the Ministry own multiple rental properties and have proceeded, in those cases, as though they are in landlord-tenant relationships with the person they seek to evict, it must mean that here, there is likewise a landlord-tenant relationship. We do not find this analysis compelling,” Baker wrote for the panel. “We do not know the facts of any of those cases … (a)ll that we know are the facts of this case. Here, the relationship between the Ministry and Pratt falls squarely under the exception to the landlord-tenant statutes.

“Therefore, the trial court erred by entering judgment in favor of Pratt and ordering the Ministry to pay damages. The judgment of the trial court is reversed and remanded with instructions to enter judgment in favor of Pfledderer and the Ministry.”

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