Johnson v. Riverside Apartments
531 S.W.3d 721 (Tex. App. 2017)
Quick Take
Johnson v. Riverside Apartments has been cited 45 times — a moderately influential decision in Landlord-Tenant law. Its citation status is "good law," meaning courts continue to follow and affirm this ruling — it remains authoritative.
How to Use This Case
When to cite:
This case has good-law status and is regularly cited in Landlord-Tenant arguments. It's appropriate to cite when you need authority on Itemized accounting requirement or Normal wear and tear distinction.
Key arguments it supports:
- An itemized list of security deposit deductions must contain specific descriptions, not vague categories
- Normal wear and tear may not be charged against a security deposit
- The landlord bears the burden of proving deductions are for damage beyond normal wear and tear
Court level & jurisdiction:
As a Texas Court of Appeals, 5th District decision, this ruling is binding within its circuit and persuasive in other jurisdictions.
Summary
The court addressed what constitutes a valid itemized list of deductions from a security deposit. The court held that a landlord's deduction list must be specific enough to allow the tenant to meaningfully evaluate each claimed deduction. Vague entries like 'cleaning' or 'damages' without further detail are insufficient.
The court further held that normal wear and tear may not be deducted from a security deposit, and the landlord bears the burden of distinguishing between normal wear and tenant-caused damage.
Key Holdings
- 1An itemized list of security deposit deductions must contain specific descriptions, not vague categories
- 2Normal wear and tear may not be charged against a security deposit
- 3The landlord bears the burden of proving deductions are for damage beyond normal wear and tear
Why This Case Matters
Provides detailed guidance on what constitutes a valid itemized accounting of security deposit deductions, helping tenants challenge vague or overbroad claims.
Facts
Tenant disputed landlord's deductions from $1,500 security deposit. Landlord's itemized list contained entries like 'carpet cleaning - $300' and 'general repairs - $450' without specifying what was repaired or why cleaning exceeded normal wear. Tenant argued deductions were for normal wear and tear.
Legal Principles
Statutes Interpreted
- Tex. Prop. Code § 92.104
- Tex. Prop. Code § 92.103
Related Cases
Patel v. City of Fort Worth
576 S.W.3d 435 (Tex. App. 2019)
The court addressed a landlord's obligation to return a security deposit under Texas Property Code § 92.103. The court held that a landlord who fails to return a security deposit or provide an itemized accounting within 30 days of the tenant vacating is presumed to have acted in bad faith. This presumption shifts the burden to the landlord to show good cause for retention.
Singh v. Oak Creek Management
612 S.W.3d 108 (Tex. App. 2020)
The court addressed the requirements for a valid notice to vacate under Texas Property Code § 24.005 prior to filing a forcible detainer action. The court held that the notice must strictly comply with statutory requirements, including identifying the property, stating the landlord's demand, and providing the required time period for compliance.
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