This is messed up!

Dear armchair lawyers:

Please stop. There is no way to answer the question without knowing what laws govern and far more information about the instant facts.

Dear Mr. Vegas,

If you need her as a reference, you're going to have to pay her. If you don't and she doesn't have a security deposit of yours, tell her you're not going to pay her and see what she does.

^^^^ I believe that is why people have already suggested he contact the tenant's association.

This of course assumes that there is one and that recommendation can be gleaned from what is, in fact an awful lot of very bad advice.

I am a lawyer and wouldn't presume to give an opinion here.

What he said.

Find out what the law is in your area. Don't take speculation as legal advice.