When a tenant fails to pay rent, eviction is expected. But what about when a tenant does pay rent, yet fails to comply with other non-monetary lease obligations? A recent Minnesota Court of Appeals decision confirms that even in the absence of monetary damages, a tenant can still be evicted for breaching a key lease provision. In 515 W. Lake LLC v. Ikram Childcare Center LLC, No. A23-1266, 2025 WL 1243153 (Minn. Ct. App. Mar. 31, 2025), a nonprecedential opinion, except as provided by Minn. R. Civ. App. P. 136.01, subd. 1(c), the court upheld eviction based solely on the tenant’s failure to maintain insurance in compliance with the lease.
Ikram Childcare Center (“Tenant”) leased space from 515 W. Lake LLC (“Landlord”) to operate a daycare. The lease required Tenant to maintain property and liability insurance for the benefit of both parties, as well as to pay utilities and cover a share of property taxes, among other things. Although Tenant consistently paid base rent, it failed to pay its share of property taxes and utilities. In addition, Tenant failed to obtain any insurance for the first eight months, and when it finally did, the policy did not name Landlord as an additional insured, as required by the lease.
Landlord issued a termination notice and sued for eviction, citing multiple breaches, including Tenant’s failure to maintain proper insurance coverage. The court found that most of the alleged breaches (including Tenant’s failure to pay utilities and taxes) had been waived but granted eviction based solely on the ongoing insurance violation.
On appeal, Tenant argued that eviction was improper because Landlord had not suffered any damages. The Court of Appeals rejected that position, holding that under Minnesota law, a landlord need not prove damages in an eviction action—only that a material breach occurred. Eviction is a possessory remedy, not a damages claim.
Tenant also contended that its failure to maintain insurance was not a material breach. The court disagreed. It held that the prolonged absence of coverage, followed by noncompliant coverage even after notice, constituted a material breach of the lease. The Court of Appeals affirmed the district court’s ruling, noting that the lease expressly required insurance coverage for the benefit of both parties, including naming the Landlord as an additional insured.
This decision is a clear reminder that a lease is more than just a rent arrangement—it’s a bundle of negotiated rights and obligations. Some defaults aren’t about dollars; they’re about risk. Even in the absence of actual harm, a tenant’s failure to maintain insurance or comply with other material non-monetary obligations can be enough to justify eviction. Courts will enforce these provisions as written, making it all the more important for both landlords and tenants to ensure that lease terms are clearly drafted and reflect the parties’ expectations.