OPINION

GILDEA, Chief Justice.

In this subrogation action, appellant RAM Mutual Insurance Company seeks to recover payment it made to its insured for the repair of water damage allegedly caused by the negligence of respondent Rusty Rohde, the commercial tenant of RAM's insured. The district court granted Rohde's motion for summary judgment, dismissing RAM's subrogation claim as a matter of law, relying on the court of appeals decision in United Fire & Casualty Co. v. Bruggeman, 505 N.W.2d 87 (Minn.App.1993), rev. denied (Minn. Oct. 19, 1993). The court of appeals affirmed. RAM Mut. Ins. Co. v. Rohde, 805 N.W.2d 554, 557 (Minn.App.2011). We reject the rule from Bruggeman and conclude that the question of whether an insurer may pursue a subrogation action against the tenant of an insured, when the tenant's negligence caused damage to the insured's property, must be answered by examining the unique facts and circumstances of each case. Therefore, we reverse and remand.

This action arises out of the landlord and tenant relationship between JD Property Management, LLC, and Rusty Rohde. JD Property owns a rental property in Sauk Centre, Minnesota, containing three business suites. Rohde rents one of the suites and operates a salon business, the Studio 71 Salon, in the leased premises. Rohde's rental is governed by a 5-year commercial lease agreement (the "lease") with JD Property.

After taking possession of the leased premises, Rohde replaced two pedicure chairs in his salon and installed water lines serving the chairs. In February 2008, one of the water lines allegedly burst, causing water damage to the Studio 71 Salon suite as well as an adjacent suite. JD Property filed an insurance claim with its property insurer, RAM, requesting payment for the water damage. RAM paid JD Property $17,509, the full amount of JD Property's claim, to repair the damage.1 Because Rohde had installed the water line, allegedly without JD Property's knowledge in violation of the lease, RAM filed a subrogation action against Rohde, asserting breach of contract, negligence, and promissory estoppel. As subrogee of JD Property, RAM sought recovery of the $17,509 paid to JD Property for repair of the damage at the insured premises.

Rohde brought a motion for summary judgment, relying upon a line of cases from the Minnesota Court of Appeals beginning with United Fire & Casualty Co. v. Bruggeman, 505 N.W.2d 87 (Minn.App. 1993), rev. denied (Minn. Oct. 19, 1993). Rohde argued that Bruggeman barred RAM's subrogation claim, regardless of whether Rohde was at fault for the losses occasioned by the water damage, because Rohde "as a tenant, is a co-insured under the RAM policy." The district court granted Rohde's motion, determining that resolution of the case was governed by Bruggeman. Based on Bruggeman, the district court found that Rohde was a co-insured for purposes of JD Property's insurance policy. Because general principles of insurance law prohibit an insurer from bringing a subrogation claim against a co-insured, see 16 Lee R. Russ & Thomas F. Segalla, Couch on Insurance § 224:1 (3d ed.1995), the court dismissed RAM's complaint with prejudice as a matter of law.

The court of appeals affirmed. RAM Mut. Ins. Co. v. Rohde, 805 N.W.2d 554 (Minn.App.2011). The court determined that the lease placed no express obligation on either JD Property or Rohde to procure property insurance providing coverage for the water damage at issue, and that under Bruggeman, Rohde was a co-insured under the RAM insurance policy. Id. at 556. Because Rohde was a co-insured, the court held that "RAM cannot maintain a subrogation action against Rohde." Id. at 557. We granted RAM's petition for review.

I.

This case presents the question of whether an insurer may maintain a subrogation action against the insured's negligent tenant.2 Subrogation "is the substitution of another person in place of the creditor to whose rights he or she succeeds in relation to the debt, and gives to the substitute all the rights, priorities, remedies, liens, and securities of the person for whom he or she is substituted." 16 Lee R. Russ & Thomas F. Segalla, Couch on Insurance § 222:5 (3d ed.1995). In the insurance context, subrogation "involves the substitution of an insurer (subrogee) to the rights of the insured (subrogor)." Medica, Inc. v. Atl. Mut. Ins. Co., 566 N.W.2d 74, 76 (Minn.1997). Upon payment of a loss, the insurer is subrogated in a corresponding amount to the insured's right of action against any third party whose wrongful conduct caused the loss. See Blair v. Espeland, 231 Minn. 444, 446, 43 N.W.2d 274, 276 (1950); see also Buell v. United Firemen's Ins. Co., 167 Minn. 183, 185, 208 N.W. 819, 820 (1926). Subrogation arises "only with respect to rights of the insured against third persons to whom the insurer owes no duty"; consequently, "it has long been held that no right of subrogation can arise in favor of an insurer against its own insured." Russ & Segalla, supra, § 224:1; see also Wager v. Providence Ins. Co., 150 U.S. 99, 108, 14 S.Ct. 55, 37 L.Ed. 1013 (1893). This basic principle extends to prohibit an insurer from bringing a subrogation action against its co-insured. See Rausch v. Allstate Ins. Co., 388 Md. 690, 882 A.2d 801, 807 (2005) (explaining that there can be no subrogation of an insurer against its own insured "because, as subrogee, the insurer stands in the shoes of the insured," and subrogation against an insured would therefore "essentially involve the insured suing himself to recover damages he sustained by his own conduct").

In response to Rohde's motion for summary judgment, the district court concluded that subrogation was not available based on the court of appeals decision in United Fire & Casualty Co. v. Bruggeman, 505 N.W.2d 87 (Minn.App.1993), rev. denied (Minn. Oct. 19, 1993). When considering an "appeal from summary judgment, we must determine whether there are any genuine issues of material fact, and whether the lower court erred in its application of the law." Olmanson v. LeSueur Cnty., 693 N.W.2d 876, 879 (Minn. 2005). We review the district court's "legal decisions on summary judgment under a de novo standard," SCI Minn. Funeral Servs., Inc. v. Washburn-McReavy Funeral Corp., 795 N.W.2d 855, 861 (Minn.2011), and "view the evidence in the light most favorable to the party against whom judgment was granted," Fabio v. Bellomo, 504 N.W.2d 758, 761 (Minn.1993).3

A.

Because the district court and court of appeals determined that Bruggeman was dispositive, we turn first to a discussion of that case. In Bruggeman, the court of appeals sought to interpret the application of basic subrogation principles to the specific question of when a landlord's insurer may bring a subrogation action against the landlord's negligent tenant. 505 N.W.2d at 88. The case arose when the landlord's property insurer brought a subrogation action against the tenants, alleging that the tenants had negligently caused fire damage to the landlord's building. Id. No written lease governed the landlord-tenant relationship, and the parties had no agreement regarding the provision of fire insurance. Id. But the landlord had purchased insurance, which provided coverage for the damage at issue. Id.

The Bruggeman court, following what it described as the "the majority position," determined that "the landlord and the tenant were co-insureds because each had an insurable interest in the property — the landlord a fee interest and the tenant a possessory interest." Id. at 88-89. The court grounded this result in its determination that by paying rent, tenants indirectly pay a landlord's insurance premiums. Id. at 89. Because an insurer cannot bring a subrogation action against its own insured, the court concluded that the tenants, as co-insureds of the landlord, were "not subject to subrogation" by the insurer. Id. at 90.

The court further reasoned that denying subrogation efficiently allocated economic resources because if "each tenant is responsible for all damages arising from its negligence in causing a fire and if each tenant was therefore responsible for its own fire insurance, the same property would be insured many times over." Id. at 89. Moreover, the court stated that its holding that a landlord and tenant were co-insureds was consistent with the expectations of an insurer insuring rental property. Id. Even though an insurer "may not have control over who the individual tenants are," the court determined that "[t]he insurer knows the risk it is undertaking when insuring a rental property" and "can increase its premiums to reflect increased risks presented by changing tenant use." Id.

The court of appeals has followed the Bruggeman approach as the default rule in cases in which the parties to a lease have no express agreement regarding the procurement of insurance to cover the particular loss at issue. See, e.g., Bigos v. Kluender, 611 N.W.2d 816, 822 (Minn.App.2000) (explaining in a case of fire damage that the Bruggeman rule applies "unless an express agreement was entered into between the insured and its tenant requiring the tenant to carry its own fire insurance"), rev. denied (Minn. July 25, 2000); St. Paul Cos. v. Van Beek, 609 N.W.2d 256, 257-58 (Minn.App.2000), rev. denied (Minn. June 27, 2000). The court of appeals has extended Bruggeman to circumstances in which property damage occurs and a lease requires a tenant to carry insurance for liabilities and business operations, but does not require the tenant to carry property insurance. See Blohm v. Johnson, 523 N.W.2d 14, 16 (Minn.App. 1994). The court of appeals has, however, declined to extend Bruggeman to nonstructural and uninsured losses. See Nuessmeier Elec., Inc. v. Weiss Mfg. Co., 632 N.W.2d 248, 252 (Minn.App.2001) (explaining that because "Bruggeman's rationale relies on the landlord and tenant's shared insurable interest which is limited to the structure ... the doctrine does not shield a tenant from liability for nonstructural losses" or from "losses incurred by the owner that are not covered by insurance"), rev. denied (Minn. Oct. 16, 2001).

B.

With this background in mind, we turn to the parties' arguments regarding the applicability of United Fire & Casualty Co. v. Bruggeman, 505 N.W.2d 87 (Minn. App.1993), rev. denied (Minn. Oct. 19, 1993). We begin with the preliminary question of whether Bruggeman is applicable in this case. This is a threshold question because if we determine that the rule from Bruggeman is inapplicable to the facts presented here, we would not need to address RAM's argument urging us to reject Bruggeman.

Rohde argues that Bruggeman controls because the lease did not contain an express provision requiring either Rohde or JD Property to purchase insurance covering water damage to the property, and therefore Rohde must be considered a co-insured on JD Property's insurance. Because an insurer cannot maintain a subrogation action against its own insured or a co-insured, see U.S. Fire Ins. Co. v. Ammala, 334 N.W.2d 631, 634 (Minn.1983), Rohde contends that RAM cannot sue him for negligence and breach of contract.

RAM contends, however, that Bruggeman is inapplicable. RAM argues that Bruggeman applies only when there is no express agreement between the parties regarding responsibility for the loss at issue and that the lease here contains the requisite express agreement. RAM also contends, in the alternative, that Bruggeman is distinguishable on its facts and therefore not applicable.

We turn first to RAM's argument that Bruggeman does not apply because, unlike in Bruggeman, the lease here contains an express agreement that requires Rohde to pay for the damages he caused. The lease between JD Property and Rohde contains several provisions potentially relevant to the question of Rohde's responsibility for repairing the water damage. For example, the lease places several obligations on Rohde with respect to insurance. Under the heading "Insurance," the lease provides:

Rohde obtained an insurance policy providing third-party liability coverage as required by Paragraph 26 of the lease. Rohde's liability insurance insured the premises that Rohde leased, and through an endorsement included coverage for property damage to "[p]roperty you own, rent or occupy, including any costs or expenses incurred by you, or any other person, organization or entity, for repair, replacement, enhancement, restoration or maintenance of such property." Rohde's policy also included the coverage recommended in Paragraph 25 of the lease, providing first-party property insurance covering Rohde's personal property.4

The lease also contains several provisions relevant to this case governing the obligations of JD Property and Rohde relating to alterations of, and damages to, the leased premises. Under the heading "Tenant's Repairs and Alterations," the lease provides:

Additionally, RAM notes that the lease obligates JD Property to make certain repairs to the leased premises, providing:

The lease also specifies that at the end of the lease term "the Tenant will quit and surrender the Premises in as good a state and condition as they were at the commencement of this Lease, reasonable use and wear and damages by the elements excepted." Upon termination of the lease, Rohde agreed to be liable for the "reasonable expenses as the Landlord incurs ... in ... keeping the Premises in good order, repairing the same and preparing them for reletting."

RAM advances three arguments to support its theory that, based on the provisions discussed above, the lease contains an express agreement obligating Rohde to pay for damages caused by his negligence. First, RAM argues that the lease expressly required Rohde to obtain liability insurance covering the water damage that occurred. Second, RAM argues that the clause requiring Rohde to surrender the leased premises "in as good a state and condition as they were at the commencement of this lease," constitutes an express agreement allocating responsibility to the tenant for any water damage. Third, RAM argues that because the lease expressly "required the landlord to insure against the peril of fire," but did not require that JD Property insure against any other hazards, the parties must have intended for Rohde to insure the property against perils other than fire. Based on its conclusion that there was an express agreement between the parties, RAM contends that Bruggeman is inapplicable. We disagree.

At most, RAM's arguments identify clauses in the lease that implicitly define expectations regarding which party to the lease would be responsible for the type of water damage that occurred here. No part of the lease expressly places responsibility upon Rohde to insure against or bear responsibility for water damage. See Peterson v. Silva, 428 Mass. 751, 704 N.E.2d 1163, 1165 (1999) (finding no express agreement when the lease required the tenants to "indemnify [the landlord] from all loss resulting from their carelessness, neglect, or improper conduct" because "the lease's general language [wa]s not sufficient to create liability in the tenants" for losses from a negligently-caused fire). Our analysis of the lease establishes that, similar to Bruggeman, there was no express agreement between the parties as to who would bear the financial responsibility for the damage at issue in this case.

In addition to its argument that Bruggeman does not apply because the lease contains an express agreement allocating responsibility, RAM also argues that Bruggeman is factually distinguishable in several respects. Specifically, RAM argues that Bruggeman is inapplicable because Bruggeman involved fire rather than water damage; dealt with a residential, not a commercial, lease; and involved complete destruction, instead of minor damage, to the leased property. While RAM correctly identifies factual differences between Bruggeman and this case, RAM fails to provide any reason why these factual differences would compel a different legal conclusion if this court were to apply the rule of law from Bruggeman in this case.5 We turn to that question now.6

II.

Courts have followed three different approaches in answering the question of whether an insurer may maintain a subrogation action against an insured's negligent tenant. See Tri-Par Invs., L.L.C. v. Sousa, 268 Neb. 119, 680 N.W.2d 190, 194 (2004) (describing the question of whether a landlord's insurer can maintain a subrogation action against a tenant as "a dispute that has raged in subrogation jurisprudence for the last 30 years"). Some courts, like the court of appeals in Bruggeman, have adopted a no-subrogation rule, barring insurers from pursuing subrogation claims against negligent tenants in the absence of an express agreement to the contrary. See, e.g., N. River Ins. Co. v. Snyder, 804 A.2d 399, 403-04 (Me.2002).7 A second group of courts has adopted the opposite approach — a pro-subrogation rule that allows insurers to pursue subrogation claims against their insureds' tenants, absent an express agreement governing the provision of property insurance. See, e.g., Neubauer v. Hostetter, 485 N.W.2d 87, 89-90 (Iowa 1992).8 Other jurisdictions have pursued a middle ground, adopting a case-by-case approach to subrogation claims in the landlord-tenant context, by which courts determine the availability of subrogation based on the reasonable expectations of the parties under the facts of each case. See, e.g., Am. Family Mut. Ins. Co. v. Auto-Owners Ins. Co., 757 N.W.2d 584, 594 (S.D.2008); Rausch v. Allstate Ins. Co., 388 Md. 690, 882 A.2d 801, 814-15 (2005).9

We agree with the reasoning of the Maryland Court of Appeals and the South Dakota Supreme Court, in Rausch and Am. Family Mutual Insurance Co., and conclude for several reasons that the case-by-case approach "provides an adequate and supportable analytical framework," Rausch, 882 A.2d at 815, and is the soundest method to evaluate when an insurer has a subrogation right against an insured's tenant. First, the case-by-case approach is best suited to the areas of law implicated by the subrogation question posed by this case. The question presented by RAM's subrogation action arises at the intersection of insurance law and landlord-tenant law governing the relationship of landlords and tenants. Both areas of law are grounded in contractual relationships, making a rule that reaches a result by examining the parameters of the relationship between an insurer and insured and a landlord and tenant, as defined in the parties' respective contracts, superior to one that makes legal assumptions that do not comport with the parties' reasonable expectations. See Am. Family Mut. Ins. Co., 757 N.W.2d at 594 (concluding that the case-by-case approach "is the best approach to employ in the landlord-tenant context because it applies basic contract principles"). By examining the reasonable expectations of the contracting parties to determine whether subrogation is appropriate in a particular case, the case-by-case approach avoids the legal assumptions of the other approaches, and thus best effectuates the intent of the parties by eliminating presumptions altogether. While the case-by-case approach does not provide the same kind of predictability that accompanies either the pro- or no-subrogation approaches, the case-by-case method provides more predictability to parties by simply enforcing the terms of their contracts.

Second, the case-by-case approach best effectuates the intent of the contracting parties while still taking into account the equitable principles underlying subrogation actions. See Medica, Inc. v. Atl. Mut. Ins. Co., 566 N.W.2d 74, 77 (Minn.1997) (noting that subrogation is based on the equitable principle "`that no one should be enriched by another's loss'" (quoting 6A John A. Appleman, Insurance Law & Practice § 4054, at 143 (1972))). Because, as a matter of subrogation law, an insurer merely steps into the shoes of its insured, it would be inequitable to allow, as pro-subrogation courts do, subrogation in cases in which the parties to the lease did not reasonably expect that the tenant would be liable to the landlord for the type of damage at issue. See Rausch, 882 A.2d at 816 (explaining that "[i]f, and to the extent that, the lease relieves the tenant of liability" for the type of damage at issue, whether caused by the tenant's negligence or not, "there can be no subrogation claim against the tenant because there would be no liability to the landlord in the first place"). Similarly, it would be inequitable to bar an insurer's subrogation action when the landlord and tenant expected the tenant to be liable for particular damages. Moreover, presumptive, bright-line rules of any kind are in conflict with the basic principles of equity, which by definition require a court to weigh and balance the equities between the parties in determining whether subrogation is available in a particular case. See Citizens State Bank v. Raven Trading Partners, Inc., 786 N.W.2d 274, 285 (Minn.2010).

Finally, the case-by-case method is more consistent with Minnesota's public policy of holding tortfeasors accountable for their actions than the no-subrogation approach adopted by Bruggeman. See Solberg v. Minneapolis Willys-Knight Co., 177 Minn. 10, 12, 224 N.W. 271, 272 (1929) (determining that the existence of insurance covering an injured party "is not a fact which lessens the liability of a defendant for a tort"). In the absence of a lease provision to the contrary, a tenant is generally liable in tort to its landlord for damages to the leased property caused by the tenant's negligence. See 1 Milton R. Friedman & Patrick A. Randolph, Jr., Friedman on Leases § 9:10 (5th ed.2004). The Legislature has emphasized this public policy in promulgating the statutes that govern the landlord-tenant relationship. For example, Minn.Stat. § 504B.131 (2010) provides that a tenant or occupant of a building that "is destroyed or becomes uninhabitable" may "vacate and surrender such a building" but only provided that the destruction is "through no fault or neglect of the tenant." See also Minn.Stat. § 504B.161, subd. 1(a)(2) (2010) (eliminating a landlord's duty to make repairs of residential premises when "the disrepair has been caused by the willful, malicious, or irresponsible conduct of the tenant"). These statutes support the conclusion that, in general, a tenant should be held responsible for damages caused by his own wrongful conduct. The case-by-case approach achieves this purpose by allowing an insurer to bring a subrogation action when the reasonable expectations of the parties, as evidenced by the lease, reveal that the parties did not intend to limit application of the general rule of a tenant's tort liability. Therefore, the case-by-case approach is consistent with the policy that a loss should typically be borne by the person responsible for that loss.

For all of these reasons, we conclude that the case-by-case approach is the framework best suited to ascertaining whether an insurer may maintain a subrogation action against the negligent tenant of its insured. While we could apply that rule on appeal and assess whether the parties' expectations could be determined on this record, we decline to do so for two reasons. First, the district court applied the default rule from Bruggeman. Because we have now rejected the Bruggeman rule in favor of a case-by-case approach, remand is appropriate to give the district court the opportunity to apply the case-by-case approach. See Thiele v. Stich, 425 N.W.2d 580, 582 (Minn.1988) (explaining that our court "generally consider[s] `only those issues that the record shows were presented and considered by the trial court in deciding the matter before it'" (quoting Thayer v. Am. Fin. Advisers, Inc., 322 N.W.2d 599, 604 (Minn. 1982), abrogated on other grounds by Onvoy, Inc. v. SHAL, LLC, 669 N.W.2d 344 (Minn.2003))); see also Oganov v. Am. Family Ins. Grp., 767 N.W.2d 21, 24 n. 1 (Minn.2009). Second, in addition to issues of contract interpretation, this case also involves the question of equitable relief. The district court is in the best position to "balance the equities of the case and determine whether the equitable remedy ... is appropriate." Dakota Cnty. HRA v. Blackwell, 602 N.W.2d 243, 244 (Minn. 1999); accord Flynn v. Sawyer, 272 N.W.2d 904, 910 (Minn.1978) (explaining that equitable remedies are "addressed to the sound discretion of the trial court"). But in remanding, we do not suggest that the district court would be unable to determine the availability of subrogation in the present case on summary judgment.

III.

While the analysis under the approach we have adopted is "largely a case-by-case one," there are general underlying principles of contract, subrogation, and landlord-tenant law that will aid courts that undertake a case-by-case analysis in determining the reasonable expectations of the parties. Rausch, 882 A.2d at 815. To provide guidance on remand, we turn next to a discussion of the general principles that inform the application of the case-by-case approach.

To determine whether RAM's subrogation claim is barred under the case-by-case approach, the district court must ascertain the expectations of the parties as to which party bears responsibility for a particular loss. See Am. Family Mut. Ins. Co. v. Auto-Owners Ins. Co., 757 N.W.2d 584, 594 (S.D.2008). The case-by-case analysis begins with the written documents executed by the parties.10 See Bannock Bldg. Co. v. Sahlberg, 126 Idaho 545, 887 P.2d 1052, 1056 (1994) (directing lower courts to "focus on the terms of the lease agreement itself to determine what the reasonable expectations of the parties were as to who should bear the risk of loss for ... damage to the leased premises"). Examining the lease agreement to determine the expectations of the parties rests on the well-established principle that leases are contracts to which we apply general principles of contract construction. See Minneapolis Pub. Hous. Auth. v. Lor, 591 N.W.2d 700, 704 (Minn.1999) (explaining that "a lease is a form of contract"). The district court therefore should interpret provisions in a lease governing a tenant's liability for a particular loss according to the fundamental principle that the "goal of contract interpretation is to ascertain and enforce the intent of the parties." Valspar Refinish, Inc. v. Gaylord's, Inc., 764 N.W.2d 359, 364 (Minn.2009). To this end, provisions of a lease "should never be interpreted in isolation, but rather in the context of the entire agreement." Hydra-Mac, Inc. v. Onan Corp., 450 N.W.2d 913, 916 (Minn.1990). When the language of a lease is unambiguous, it should be "given its plain and ordinary meaning." Metro. Airports Comm'n v. Noble, 763 N.W.2d 639, 645 (Minn.2009); see also Hydra-Mac, Inc., 450 N.W.2d at 916 (explaining that with contracts generally, "the language employed should be given its plain meaning"). And when language is ambiguous, it should be construed against the drafter. See Hilligoss v. Cargill, Inc., 649 N.W.2d 142, 148 (Minn.2002).

In determining the expectations of the parties as articulated in the lease, courts should look for evidence indicating which party agreed to bear the risk of loss for a particular type of damage.11 Fundamentally, the determination of whether an insurer may bring a subrogation action is circumscribed by the nature of a subrogation action, whereby "there is no right of subrogation unless there is liability in the first instance by the tenant to the landlord." Rausch, 882 A.2d at 816. Therefore, if a lease expressly provides that the tenant is not responsible for a particular loss, the landlord could not bring an action against the tenant in the first instance, and there would accordingly be no right of subrogation on the part of the insurer. Moreover, if the lease indicates that the landlord has agreed to procure insurance covering a particular loss, a court "may properly conclude that, notwithstanding a general `surrender in good condition' or `liability for negligence' clause in the lease," the landlord and tenant reasonably expected "that the landlord would look only to the policy, and not to the tenant, for compensation for ... loss[es] covered by the policy." Id. In such a case, the insurer would again not be able to maintain a subrogation action, because the landlord would be unable to sue the tenant for the damage under the lease. If, however, a lease obligates a tenant to procure insurance covering a particular type of loss, such a provision will provide evidence that the parties reasonably anticipated that the tenant would be liable for that particular loss, which would allow another insurer who pays the loss to bring a subrogation action against the tenant. See Am. Family Mut. Ins. Co., 757 N.W.2d at 593 (concluding that "subrogation may be appropriate where the lease does not require the landlord to purchase [property] insurance or the lease requires the tenants to purchase their own insurance to cover liabilities resulting from their negligence").

Often a court will be able to determine the expectations of the parties from the language of the lease itself. See Fire Ins. Exch. v. Hammond, 83 Cal.App.4th 313, 99 Cal.Rptr.2d 596, 600-02 (2000); Sahlberg, 887 P.2d at 1056. But, in addition to the actual language of a lease or insurance policy, courts engaged in a case-by-case analysis may also examine "any other admissible evidence" shedding light on the expectations of the parties. Rausch, 882 A.2d at 814. Such evidence could include, among other things, the types of insurance purchased by each party as evidence of each party's expectations with respect to its responsibility for particular losses. See Am. Family Mut. Ins. Co., 757 N.W.2d at 594.

Finally, because subrogation is an equitable remedy, in determining whether an insurer may bring a subrogation action in a particular case, courts must weigh "the principles of equity and good conscience." Dix Mut. Ins. Co. v. LaFramboise, 149 Ill.2d 314, 173 Ill.Dec. 648, 597 N.E.2d 622, 626 (1992) (explaining that the equities of the case should be considered in addition to examining "the provisions of the lease as a whole [and] the reasonable expectations of the parties"); Am. Family Mut. Ins. Co., 757 N.W.2d at 595 (allowing an insurer to maintain a subrogation action after examining the lease and "[c]onsidering the equitable underpinnings of subrogation"). In balancing the equities, the court may consider, among other factors, whether the lease is a contract of adhesion, and if the provisions allocating responsibility "are found to be unfair," may declare such provisions "invalid as being in violation of public policy." Rausch, 882 A.2d at 815; cf. Schlobohm v. Spa Petite, Inc., 326 N.W.2d 920, 924-25 (Minn.1982) (explaining that contracts of adhesion, characterized by a disparity of bargaining power between the parties and forced upon an unwilling public for services that cannot readily be obtained elsewhere, will not be enforced). Moreover, the fact that the leased premises are part of a large multi-unit structure may be relevant to the equities and the parties' reasonable expectations regarding responsibility. This factor may be relevant because, in the absence of a "very clear contractual obligation to the contrary," the tenant likely is not "thinking beyond the leased premises" and may not "as a practical matter ... be able to afford, or possibly even obtain, sufficient liability insurance to protect against such an extended loss." Rausch, 882 A.2d at 816.

In sum, under our case-by-case approach, consistent with the principles outlined above, an insurer will be able to maintain a subrogation action where, based on "the lease as a whole, along with any other relevant and admissible evidence," the district court determines that "it was reasonably anticipated by the landlord and the tenant that the tenant would be liable, in the event of a [tenant-caused property] loss paid by the landlord's insurer, to a subrogation claim by the insurer." Rausch, 882 A.2d at 816.

Reversed and remanded for proceedings consistent with this opinion.