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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Bernstein v. Fernandez, 649 A.2d 1064 (1991)

Citation
Bernstein v. Fernandez, 649 A.2d 1064 (1991)
Parent Document
Bernstein v. Fernandez, 649 A.2d 1064 (1991)
Jurisdiction
DC (municipal)
Effective Date
1991-03-28

Other Sections in This Document (123)

Full Text

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We reach the same conclusion regarding the breach of warranty of habitability. Although this court has noted that the concept of such a breach developed as a hybrid of tort and contract claims, Berman v. Watergate West, Inc., 391 A.2d 1351, 1355 (D.C.1978), the warranty of habitability is implied in leases, and, as is true of most modern warranties, a claim for a breach is essentially a contract cause of action. Id. H & M’s breach of the warranty of habitability did not merge with a tort to support an award of punitive damages. Sere, supra, 443 A.2d at 37.14 F. Other contentions