Lefrak v. Lambert

The Lamberts (defendants) signed a three-year lease with Lefrak (plaintiff) containing a clause stating the landlord had no duty to mitigate damages upon breach; they vacated over nine months before the lease ended while two months behind on rent, and the apartment sat vacant for seventeen months before being re-rented. Lefrak sued for unpaid rent and fees totaling $5,462, but the trial court found Lefrak failed to prove any good-faith effort to re-rent the unit.