Minnesota Statutes

Minn. Stat. § 504B.121 (2026)

Tenant May Not Deny Title; Exception

✓ current as of May 2026

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A tenant in possession of real property under a lawful lease may not deny the landlord's title in an action brought by the landlord to recover possession of the property. This prohibition does not apply to a tenant who, prior to entering into the lease, possessed the property under a claim of title that was adverse or hostile to that of the landlord.

Notes of Decisions

Cited in 5 cases, 2006–2015 · leading case: Real Est. Equity Strategies, LLC v. Jones, 720 N.W.2d 352 (Minn. Ct. App. 2006).

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Real Est. Equity Strategies, LLC v. Jones, 720 N.W.2d 352 (Minn. Ct. App. 2006). · cites it 26× “Amici also note that Minn.Stat. § 504B.121 (2004) allows a tenant, under certain circumstances, to challenge a landlord’s title to property in the landlord’s action to recover possession of that property.”

Fed. Home Loan Mortg. Corp. v. Gary E. Mitchell, John Doe, 862 N.W.2d 67 (Minn. Ct. App. 2015). · cites it 12× “Assuming that the Mitchells intended to cite Minn.Stat. § 504B.121 (as applied in *73 Jones), their argument fails because they are not tenants within the meaning of that section.”

U. S. Bank Nat'l Ass'n v. Blanca J. Sacta, John Doe (Minn. Ct. App. 2015). · cites it 6× “Appellants argue that Minn. Stat. § 504B.121 (2014) specifically permits them to challenge the bank’s title in this eviction action because they obtained their interest in the property before the bank obtained its interest.”

S3 Holdings, LLC v. Stephen R. Niosi, John Doe (Minn. Ct. App. 2015). · cites it 4× “Appellants argue that Minn. Stat. § 504B.121 (2014) specifically permits them to challenge respondent’s title in this eviction action because they obtained their interest in the property before respondent obtained its interest.”

U.S. Bank Nat'l Ass'n, as Tr. for the C-BASS Mortg. Loan Asset-Backed Certificates, Series 2006-RP2 v. Timothy Knoedler, Candace Knoedler, John Doe (Minn. Ct. App. 2015). · cites it 2× “This court acknowledged that “[b]ecause the current limits on the scope of eviction proceedings are not based on an inability of the district court to adjudicate disputes other than the right to present possession of the premises, a tenant who challenges a landlord’s title…”

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