55 N.Y.2d 966 (1982)
A landlord can be held liable for injuries sustained by a tenant when the landlord’s failure to repair a known dangerous condition on the property is the proximate cause of the injury, and the injury was a foreseeable consequence of the unrepaired condition.
Summary
This case addresses a landlord’s liability for injuries sustained due to the failure to repair a known dangerous condition. The plaintiff, an infant, was injured when a loose door in his family’s apartment, which the landlord had been repeatedly notified about but failed to repair, fell on him. The New York Court of Appeals, in a split decision, affirmed the lower court’s order, holding the landlord liable. The dissent argued that the injury was a foreseeable consequence of the landlord’s negligence and that the jury’s finding of foreseeability should have been decisive.
Facts
The plaintiff, a young child, lived with his family in an apartment rented from the New York City Housing Authority (the defendant). Upon moving in, the family discovered that the bedroom door was loosely hanging due to defective hinges. The mother notified the defendant about the dangerous condition of the door. Over a period of 17 months, the mother requested repairs on approximately 19 occasions. The defendant failed to repair the door. A representative of the defendant directed the mother to place the door against the wall or under the bed. While the child was playing, the door fell on him, causing serious injuries.
Procedural History
The plaintiffs sued the New York City Housing Authority for negligence. The trial court found in favor of the plaintiffs. The Appellate Division reversed the trial court’s decision. The plaintiffs appealed to the New York Court of Appeals.
Issue(s)
Whether the landlord’s failure to repair the known dangerous condition of the door was the proximate cause of the infant plaintiff’s injuries, and whether the injury was a foreseeable consequence of the landlord’s negligence.
Holding
Yes, because the court affirmed the Appellate Division’s ruling based on the memorandum provided, implicitly agreeing that the landlord’s negligence was the proximate cause and the injury was a foreseeable consequence.
Court’s Reasoning
The majority of the Court of Appeals affirmed the Appellate Division’s decision without providing detailed reasoning, relying on the memorandum from the lower court. The dissenting opinion, however, strongly argued that the injury was a foreseeable consequence of the landlord’s negligence. The dissent emphasized that the mother had repeatedly notified the landlord of the dangerous condition and that the landlord had failed to take appropriate action. The dissent stated, “Consequently, whether it was foreseeable, under all the circumstances, that the defendant’s conduct could bring injury to a child was all but a classical question of fact.” The dissent further noted that the jury had expressly found foreseeability in response to a special interrogatory. The dissent distinguished this case from Martinez v. Lazaroff, where an intervening cause broke the chain of causation. Here, the dissent argued, the unhung door was the direct and continuing cause of the injury. The dissent cited the defendant’s supervisor advising the mother that she would be held responsible if she threw the door away, indicating that the defendant was aware of the potential danger posed by the door. The dissent emphasized the importance of allowing a jury to decide questions of foreseeability in tort cases, stating that these questions are “best decided by a lay jury.”