Does he operate the rental through a business entity like a corporation, LLC, etc? And if so, where is the entity set up? If he doesn't use a U.S. limited liability business entity he probably should be doing that for U.S. tax purposes and to limit his exposure for debts of the rental operation. How the rental is set up and where will have a significant impact on the person/entity you sue, in what jurisdiction you sue, and whether small claims court would be a proper forum for your dispute.