Tenants protected from retaliatory eviction need not prove landlord’s subjective intent, only that the tenants protected actions were the “but for” cause of the eviction

Tenants who complained about the electrical system and were then evicted could prove retaliatory eviction and stave off eviction merely by showing that their protected action was the “but for” cause of the eviction. They need not prove the landlord’s subjective intent and the eviction following their complaint placed the burden on the landlord to show that the eviction was not retaliatory. Elk Creek Mgmt. Co. v. Gilbert, 303 P.3d 929 (Or. 2013).