When a tenant breaches a lease agreement, many times the landlord rushes to the courthouse to file a complaint seeking to evict the tenant from the leased premises, only later to find out that the tenant may "pay to stay" in the leased premises if the complaint is based solely upon the nonpayment of rent due under the lease agreement.

In Johnson v. Bullock-Freeman, the Superior Court of Pennsylvania recently delved into what constitutes the appropriate amount to "pay to stay," involving a monetary lease dispute between a landlord and tenant in Philadelphia County.