Marlow v. Shiffman

9 Ohio N.P. (n.s.) 533, 20 Ohio Dec. 209, 1909 Ohio Misc. LEXIS 100

This text of 9 Ohio N.P. (n.s.) 533 (Marlow v. Shiffman) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marlow v. Shiffman, 9 Ohio N.P. (n.s.) 533, 20 Ohio Dec. 209, 1909 Ohio Misc. LEXIS 100 (Ohio Super. Ct. 1909).

Opinion

Kinkead, J.

The petition alleges that she rented a certain house from the defendants in December, 1908; that to induce the renting the defendants’stated that the three wooden steps lading from the street into the house while loose and old were safe, and the defendants would soon or at once put them in complete repair.

Plaintiff says that relying upon said promise she moved into said house and lived there; and to enter said house, or depart therefrom, used said steps; that defendants frequently before the grievances complained of assured said plaintiff that said steps were safe, for walking thereon, and would be connected to said house without further delay. The petition then describes the steps, stating that they were made of wood, that the lower step was old and rotten, and the nails holding the same loosened.

[534]*534That on 'January 16, 1909, while said plaintiff was descending said steps, the wedge under said lower step and said lower step loosened, crushed and gave way, throwing the plaintiff across the sidewalk into the gutter, injuring her in the manner described in the petition.

It is then further alleged that the steps at the time of said leasing and injury were not in proper repair or a reasonably safe condition, which condition the defendants knew, or by the exercise of ordinary care should have known, when they made the lease.

Plaintiff then further avers that she was ignorant, and had no knowledge that said steps were unsafe, or dangerous, that while they were loose from the wall and old, she did not believe them to be unsafe, but only needing repair, and connecting up to said house and she relied upon said defendant’s statement that said steps were safe and the repairs needed would be made at once.

Plaintiff then alleges she was without fault or negligence, and said injury occurred by reason of said unsafe, rotten and defective steps, and also'by reason of the defendants not putting them in complete repair or safe for walking thereon. Plaintiff prays for damages in the sum of $5,000.

The evidence of plaintiff shows that she was fully aware that the steps were old and out of repair at the time she rented the property; she not only states that in her pleading but the evidence offered by her, both her own testimony as well as that of other,witnesses produced by her, shows that she knew the steps were out of repair, and that she requested that they be repaired, and that defendants promised to repair them. This, however, defendants deny. It clearly appears that the plaintiff at the time she rented the property had the opportunity of learning and knowing the condition of the steps. She says she relied upon the promise of defendants to repair them. There is no testimony to support the averment in the petition that defendants represented to plaintiff that the step's were safe. Even if there wore, it would hardly seem that plaintiff was justified in relying thereon, in view of the fact that she admits that they were in bad repair, and that she relied upon the promise to re[535]*535pair them. The allegation of such representation as to the safety of the steps is hardly consistent with the averments and evidence that she knew that they were out of repair, and that defendants promised to repair them.

A claim is made in argument that there .was a latent defect known to defendants, but not known to plaintiff. This seems impossible in view of the fact that the steps were exposed to view, to plaintiff as well as to defendants. The petition avers that they were loose; the evidence shows the same condition, the husband testifying that he fastened.them in some way so. that they would not be loose.

The evidence also shows that plaintiff continued to occupy the property notwithstanding the fact that on several occasions she requested defendants to repair the steps, which they failed to do. And finally plaintiff was compelled to quit the premises for non-payment of rent.

The court directed a non-suit and the question is now on a motion for a new trial.

The law relating to this class of cases has not been readily perceived, much misunderstanding prevails concerning it, and some inaccuracy of statement appears in the decisions with reference to the grounds of liability recognized by courts for injuries to property or to person as a result of some act of misfeasance or nonfeasance of the landlord.

The grounds of liability for injuries arising from a nuisance are to be distinguished from cases where the tenant seeks to hold the landlord responsible in tort, where the transaction is grounded in contract.

The confusion and misunderstanding comes from a failure to distinguish between the effect of the violation of a contractual duty and one imposed by law which is classed as a tort.

The violation of a duty arising by contract gives rise to a right of action for a breach thereof, and the damages recoverable are those which directly result from its breach, not those which are remote and consequential and not within contemplation of the parties.

For example, if by the terms of the contract of letting by landlord to tenant, the former as part of the consideration of [536]*536renting or leasing agrees with the latter that he will make a specific repair, as is claimed in this case^ it is the duty of the tenant for his own convenience and use of the premises as well as for his own protection from personal injury to himself or to his family, and his protection against liability to third persons arising from the defective condition of the premises, to make the needed repairs which the landlord promised to make, and recover the cost of the same in an action for breach of contract.

If the tenant continues in the.occupancy of the premises, with full knowledge of its defects, as the plaintiff did in this ease, she assumes the risks of injury to herself from the continued use of the defective steps, as well as all other responsibilities that are usually imposed upon a tenant by reason of the transfer of the premises; her continued use and occupancy imposes upon her certain legal responsibilities as to third parties, which need not be repeated here, but with which every lawyer versed in the law is familiar.

The plaintiff’s counsel in this case proceeded upon the theory .that the violation of the alleged contractual duty to repair the steps constituted an act of negligence, for which her action Jor personal injury may be had. And in his disappointment over the direction of the non-suit, he says that if the decision is to stand, there is no remedy for such a misfortune as plaintiff has suffered.

■ The law having been settled for so many years concerning this matter, this court can not make a new rule nor help the misunderstanding of counsel concerning the same.

It is dificult to conceive how one act can be considered an act of negligence and a violation of a contractual duty at the same time. This was the mistake made'by the slip of the pen in Cowen v. Sunderland, 145 Mass., 363, which brought upon the judge delivering the opinion the severe criticism of the judge in Shinkle, W. & K. Co. v. Birney, 68 Ohio St., 328, Shauck, J., designating it as a migration of the law. The judge in Cowen v. Sunderland, supra, in which case there had been a concealment of a defect known to the defendant, stated that there was an exception to the general rule of caveat empior as between lessor [537]

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Bluebook (online)
9 Ohio N.P. (n.s.) 533, 20 Ohio Dec. 209, 1909 Ohio Misc. LEXIS 100, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marlow-v-shiffman-ohctcomplfrankl-1909.