Kline v. 1500 Massachusetts Avenue Apartment Corp.

Plaintiff suffered injuries from a criminal assault & battery occuring in the common hallway of her apartment building. Security measures in the building had decreased significantly from 1959, when plaintiff signed her lease, to 1966, despite an increasing number of crimes committed against tenants.

"There is a duty of protection owed by the landlord to the tenant in an urban multiple unit apartment dwelling ...[The] standard of protection may be taken as that commonly provided in apartments of this character and type in this community ... [The landlord's] duty is to take those measures of protection which are within his power and capacity to take, and which can reasonably be expected to mitigate the risk of intruders assaulting and robbing tenants."

Affirmative Duties | Special Relationships