1. In January 1995, Lance Landlord leased his country estate to Thelma Tenant for ten years at a monthly rent of $10,000. Thelma immediately moved into the estate. Then in August 2000, while Thelma was out of the country on a weekend trip, Francis Freeloader moved into the estate and installed her bodyguards to prevent anyone - including Thelma - from entering the property. It took Thelma four months to get the local government to evict Francis so that Thelma could move back into the estate in December 2000. Thelma refuses to pay Lance any rent for the four months that Francis possessed the house. Which resulting lawsuit is most likely to be successful?

• Lance's suit against Thelma for the $40,000 unpaid rent.
• Lance's suit against Francis for the $40,000 unpaid rent.
• Thelma's suit against Lance for breach of an implied covenant if the American rule applies.
• Thelma's suit against Lance for breach of an implied covenant if the English rule applies.