Wofford v. Vavreck
Pennsylvania Court of Common Pleas, Crawford County
22 Pa. D. & C.3d 444 (1981)
The Woffords (plaintiffs) leased a mobile home under a lease clause purporting to let the landlord (defendants) take immediate possession without notice if rent went unpaid. After the Woffords fell behind, the landlords served a three-day notice demanding payment, then — when it wasn't paid — padlocked the home and cut off water and electricity rather than pursuing formal eviction proceedings. The Woffords sued for a preliminary injunction restoring possession, which the trial court granted.
Whether, in Pennsylvania, the Landlord and Tenant Act of 1951 precludes a landlord from using self-help to recover possession of a leased residence in response to a tenant's failure to pay back rent.