Humbert v. Sellars

708 P.2d 344, 300 Or. 113
CourtOregon Supreme Court
DecidedOctober 15, 1985
DocketCA A27258; SC S30581
StatusPublished
Cited by22 cases

This text of 708 P.2d 344 (Humbert v. Sellars) is published on Counsel Stack Legal Research, covering Oregon Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Humbert v. Sellars, 708 P.2d 344, 300 Or. 113 (Or. 1985).

Opinions

[115]*115PETERSON, C. J.

Plaintiff slipped and fell on a wet patio while visiting a friend’s apartment. She sought damages for injuries from the owners and manager of the apartment complex. Defendants moved for summary judgment. The trial court granted the motion. The Court of Appeals affirmed. Humbert v. Sellars, 67 Or App 176,180,677 P2d 760,762 (1984). For the reasons that follow, we reverse the Court of Appeals and remand the case to the circuit court for further proceedings.

In the' trial court defendants stated that they relied on the common-law principle that “a landlord is not subject to Usability to a tenant or a tenant’s invitees or guests for injury incurred on the premises caused by dangerous conditions which existed when the tenant took possession of the rented premises.”1 The plaintiff asserted in response that even if she could not recover under the common law, she was entitled to recover under the Residential Landlord and Tenant Act, ORS 91.700 to 91.895, specifically ORS 91.770(l)(h), which provides that “a dwelling unit shall be considered unhabitable if it substantially lacks: (h) Floors * * * maintained in good repair.” The trial court rejected plaintiffs contentions, stating:

“I rule that the Landlord-Tenant Law is not applicable to this situation, because it was not the intent of the legislature to make it so. The Landlord-Tenant Law was intended to impose a duty upon the landlord that was concurrent with the duty of the tenant to pay rent. The landlord’s duty was to maintain the premises in a habitable condition, the measure of the damages being the difference between the fair market value of the premises as they had been rented and the value of the premises during the period of breach as they actually existed. That quotation comes from the case of Lane v. Kelley, 57 Or App 197, 1982 Court of Appeals case. I can find no authority when there is no evidence of any intent on the part of the legislature to extend the requirements of this act to a guest of a tenant who is injured on the premises, thereby modifying common law in this matter.
“Because plaintiff has not made out a case under any of the exceptions of the Restatement and because there has been [116]*116no other demonstration of a duty imposed upon the landlord under the facts of this case, [the defendants are] entitled to summary judgment. * * *”

The Court of Appeals affirmed the trial court. Concerning the common-law rule, the Court of Appeals held that “with certain [inapplicable] exceptions, a lessor of land is not liable to his lessee or others on the land for harm caused by any dangerous condition which existed when the lessee took possession.” 67 Or App at 179, 677 P2d at 761. Considering ORS 91.770(1), the court stated:

“Plaintiff fails to point out or allege in her complaint which subsection of ORS 91.770 she contends was violated by the water accumulation on the patio. Although we agree that a landlord’s duty to a guest is the same as that owed to a tenant, Lyons v. Lich, 145 Or 606, 612, 28 P2d 872 (1934), we do not agree that the water on the patio falls within the statutory guidelines defining which defects amount to unhabitable premises. Plaintiffs basic argument that a guest might state a claim under ORS 91.770 may not be entirely untenable. See Brewer v. Erwin, 287 Or 435, 452, 600 P2d 398 (1979). However, without an additional assertion that defendants failed to provide one of the specifically-enumerated services mandated by ORS 91.770, the argument is irrelevant. We therefore reject plaintiffs argument that the trial court erroneously dismissed her complaint because ORS 91.770 impliedly permits her to state a claim for defendants’ breach of their duty to maintain the tenant’s premises in a habitable condition.” 67 Or App at 180, 677 P2d at 762.

I

Defendants’ motion for summary judgment was based on evidence contained in depositions of plaintiff and of defendant Taylor, who managed the property for the owners, Mr. and Mrs. Sellars. According to the evidence, the property was an apartment complex operated for low income elderly tenants under standards set by the State Housing Authority and the federal Department of Housing and Urban Development. Plaintiff occupied one of the other apartments in the complex.

On the day she was injured, the plaintiff visited her neighbor in the adjoining apartment. In front of the neighbor’s apartment was a patio, enclosed by a fence. The evidence suggests that the patio was within the premises leased to the [117]*117neighbor. It had been raining, and there was standing water on the patio in front of the entry to the neighbor’s apartment. The water was as deep as plaintiffs oxford shoes, reaching up to a cement step in front of the door. She successfully entered the apartment, but on the return trip she slipped in the water and fell, causing her injuries. Some kind of board had been placed on the patio for the purpose of stepping above standing water, but it was some distance away from the cement step and plaintiff did not recall stepping on it.

An affidavit executed by the host neighbor stated that she had had a water problem on the patio since 1978, some three years before the incident. Defendant Taylor, who managed the apartments for the other defendants, testified that he began managing the property in February, 1980, and that the previous property manager told him of the problem. The accident happened in July, 1981.

II

In her petition for review, the plaintiff urges that we should “abolish the immunity afforded to landlords and * * * apply general negligence principles to the relationship between landlords and tenants.”2 We need not reach that question because we hold that there is evidence showing a violation of ORS 91.770, and defendant therefore was not entitled to summary judgment. ORCP 47C.

Minimum standards of safety and fitness for human habitation have not been left to private ordering and the inventiveness of common-law courts; they have long been imposed by state and local lawmakers. A landlord’s duties under housing codes and the more recent landlord-tenant acts generally are enforceable by public officials or by special civil remedies accorded the tenant. Love, Landlord’s Liability for Defective Premises: Caveat Lessee, Negligence, or Strict Liability? 1975 Wis L Rev 19, 42-48. Some acts spell out the [118]*118consequences if a landlord’s noncompliance results in personal injuries,3 but many do not.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. KA-3 Associates, LLC
374 Or. 1 (Oregon Supreme Court, 2025)
Holt v. Nicoletti
341 Or. App. 748 (Court of Appeals of Oregon, 2025)
Jackson v. KA-3 Associates, LLC
Court of Appeals of Oregon, 2024
Crawford v. Yotty
828 N.W.2d 295 (Supreme Court of Iowa, 2013)
Kunst v. Pass
1998 MT 71 (Montana Supreme Court, 1998)
Davis v. Campbell
925 P.2d 1248 (Court of Appeals of Oregon, 1996)
Coulter Property Management, Inc. v. James
910 P.2d 397 (Court of Appeals of Oregon, 1996)
Newton v. Magill
872 P.2d 1213 (Alaska Supreme Court, 1994)
In Re Tax Appeal of McKee
861 P.2d 1386 (Court of Appeals of Kansas, 1993)
Madden v. Thomasson
859 P.2d 1190 (Court of Appeals of Oregon, 1993)
Appleberry v. Berry
779 P.2d 205 (Court of Appeals of Oregon, 1989)
Steininger v. Tosch
773 P.2d 15 (Court of Appeals of Oregon, 1989)
Bellikka v. Green
762 P.2d 997 (Oregon Supreme Court, 1988)
Jones v. Bierek
755 P.2d 698 (Oregon Supreme Court, 1988)
Bellikka v. Green
746 P.2d 255 (Court of Appeals of Oregon, 1987)
State Ex Rel. KOIN-TV, Inc. v. Olsen
711 P.2d 966 (Oregon Supreme Court, 1985)
Humbert v. Sellars
708 P.2d 344 (Oregon Supreme Court, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
708 P.2d 344, 300 Or. 113, Counsel Stack Legal Research, https://law.counselstack.com/opinion/humbert-v-sellars-or-1985.