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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Scott v. Garfield, 454 Mass. 790 (2009)

Citation
Scott v. Garfield, 454 Mass. 790 (2009)
Parent Document
Scott v. Garfield, 454 Mass. 790 (2009)
Jurisdiction
Massachusetts (state)
Effective Date
2009-09-15

Other Sections in This Document (57)

Full Text

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Where a tenant seeks to recover for economic loss under the warranty of habitability, we have held that the applicable standard is one of strict liability, rather than one of negligence (which would require that the landlord had notice of the defect). See Berman & Sons v. Jefferson, 379 Mass. 196, 198-204 (1979). We have left open the question whether, where a tenant (or, as here, a lawful visitor) seeks to recover for physical injuries caused by a breach of the warranty, the standard is one of negligence, as provided by the Restatement (Second) of Property (Landlord and Tenant) § 17.6 (1977) (requiring that landlord have notice of defect or code violation during the term of the lease), or strict liability. We need not decide the question today, because, as discussed infra, it does not affect the disposition of this case.