Adams v. Woodlands of Nashua

Mansfield Adams (plaintiff) sued Woodlands of Nashua (defendant) over a roach infestation in his apartment, claiming it violated his right to quiet enjoyment under New Hampshire landlord-tenant law. The trial court awarded him statutory (liquidated) damages for a quiet-enjoyment violation, and the landlord appealed.

Whether conditions that do not interfere with a tenant's use and possession of the leased premises violate the implied warranty of habitability rather than the right to quiet enjoyment.