Property owners owe many duties to the public at large and their tenants.  However, in Palmitesta v. Bonifazio, the court declined to extend the landlord’s duties to that of protector.

Plaintiff was a tenant of defendant’s premises who was assaulted by another tenant.  Plaintiff sued the landlord for negligence claiming that the landlord was aware of the tenant’s violent propensity, history of harassment, and criminal history, and as such, should have taken steps to evict the tenant.  The court disagreed and found that the landlord owed no duty to protect one tenant from the criminal acts of another.  The court stated that to do so would put an unreasonable burden on the landlord to hold it responsible for the acts of a third party over whom it had no control.

Knowledge of a “violent propensity” is a key phrase that provides for liability in certain circumstances, but apparently does not extend to expand the duties of a landlord where one tenant assaults another.

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