The Ohio Supreme Court has ruled that landlords have the same duty to the guests of tenants as they do to tenants to keep their common areas safe.
The case in question, Mann v. Northgate Investors, L.L.C., grew out of a 2007 incident in which a woman visited her friend's Columbus apartment. When leaving at night, she fell down a stairwell that lacked adequate lighting and was severely injured.
In the February 12 decision, the court unanimously agreed that a landlord's duty under Ohio law to “[k]eep all common areas of the premises in a safe and sanitary condition” also extends to guests of tenants. Violation of this duty is negligence per se.
For more, read the full opinion or the Columbus Dispatch report on the case.