Whether the NH statute governing tenant eviction or the NH Supreme Court's interpretation of that statute resulted in an unlawful impairment of a contract for rental housing, in violation of the Contract Clause

QUESTION(S) PRESENTED 1. Whether in regards to a contract for rental housing between a long-term resident of an extended-stay hotel property and the extended stay hotel property operator, the New Hampshire statute governing tenant eviction (ie. the NH tenant eviction statute) or the NH supreme court’s interpretation of that statute i. resulted in an unlawful impairment of a contract for rental housing between a longterm resident of an extended-stay hotel property and the extended stay hotel property, in violation of the contract clause of the constitution? and whether the failure or refusal of the NH supreme court to address or consider whether such a contract existed (or the terms thereof) because of its interpretation of the NH tenant eviction statute, constitutes an impairment or invalidation of the contract in violation of the Contract Clause of the Constitution? [NB: sub-classes of this question are as follows:] " By refusing to resolve the contract issue and/or seeking to destroy the contract between two private parties or by ignoring the existence of a tenancy contract, did the NH supreme court err in not providing a meaningful opportunity to be heard on the contract analysis issue in this case (i.e. whether there was a rental contact entered into by the parties that created tenancy rights in this case). ® Since contracts are a form of property, did the NH supreme court decision erroneously result in the unjust deprivation of property without due process of law? = By ignoring the contract issue, and passively deferring to the statute, did the lower court caused the state statute to override the contract and was the petitioner effectively denied the right to contract because the court stated that the statute states that a hotel can have no tenants (regardless of the fact that a contract for tenancy existed in this case)? = — Is the way the state statute is constructed, in saying that an occupancy in a hotel does not create tenancy rights, make it unconstitutional to the extent that it destroys the right of the parties to create a contract otherwise and did it ii abrogate the petitioner’s rights under the contract? Has the statute unconstitutionally created an irrebuttable presumption that one (including the petitioner) cannot ever under no circumstances whatsoever have a tenancy in something that calls itself a hotel? Does the state statute create a ‘conclusive presumption’ problem that implicates the constitutional right to contract in that the statute affords no chance to establish a contract that would trump the statute, nor does it not envision any possibility that two people could create a contract for a tenancy in a hotel? = Similarly, is the state statute unconstitutional because it violates the equal protection clause in that it arbitrarily and capriciously treats two classes of tenants differently (i.e. long-term residents in a hotel who have a housing rental contract versus residents in an apartment who have a housing rental contract) without any rational purpose or compelling government interest? And is it arbitrary and capricious for the state statute to say that no one can ever create a tenancy in a hotel including, for example, someone lives in a hotel in NH for 20 years, with a 20-year lease or housing rental contract with the owner of the hotel? Does this arbitrary and capricious application and classification create a due process violation? ii. is unconstitutional because it results in disparate impact race discrimination, in violation of the equal protection clause and/or the commerce clause of the constitution? ii. should find that if the petitioner has a lease or rental contract for housing, and/or if the state of NH recognizes a lease as a contract, then a tenancy exists as a matter of contract law and that the contract should not be invalidated by the NH tenant eviction statute, as a matter of constitutional law, and thus that certain due process ptotections should be afforded to such tenants. iv.