Section 3604

Citation: Section 3604
Parent Document: Francis v. Kings Park Manor, Inc., 944 F.3d 370 (2019)
Jurisdiction: United States (federal)
Effective Date: 2019-12-06
Original Source: https://www.courtlistener.com/opinion/4684833/francis-v-kings-park-manor-inc/ ↗

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11  There are other potential common law doctrines relevant to a landlord’s
responsibility for the behavior of third parties, but those sound in contract and property
law rather than tort. See, e.g., Park W. Mgmt. Corp. v. Mitchell, 47 N.Y.2d 316, 329 (N.Y.
1979) (concluding that a janitorial strike violated the implied warranty of habitability).
They are thus less pertinent here, given the Supreme Court’s conclusion that in the FHA,
Congress “legislate[d] against a legal background of ordinary tort‐related vicarious
liability rules and consequently intends its legislation to incorporate those rules.” Meyer,
537 U.S. at 285 (emphases added).

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