Kline v. 1500 Massachusetts Avenue Apartment Corp.

1970

Court: DC Circuit Court

Facts: Security guards are being let go from the apartment, and doors aren't covered. Assault and robbery inside the building, rather predictably.

Posture: Appeal from trial, with some sort of finding for the landlord.

Issue: Whether a duty should be placed on a landlord to take steps to protect tenants from forseeable criminal acts committed by third parties.

Holding: Yes.

Rule: There is a duty of care.

Reasoning: Landlord is the only one in a position to take action. Police can't be patrolling inside of buildings. Everyone has the duty to minimize opportunities for crime. Via Javins, there's an implied obligation to provide reasonable conditions.

Dicta: Yes, in some cases, this implies major expenses, and this will raise rents; but as it stands, tenants are already bearing these costs, in the form of the crimes to which they are victims.