Don’t Let the Bed Bugs Bite: Landlord Prevails in Premises Liability Action After Taking Appropriate Steps Upon Notification

In Clarizio v Forbes, et al., the appellate court upheld the trial court’s decision that the Defendant-Landlord was entitled to summary disposition in Plaintiffs-Tenants’ premises liability claim stemming from a variety of negligence theories involving a bed bug infestation at the property. The Court ultimately determined that Defendant demonstrated sufficient evidence to establish that he did not know or have reason to know of bed bugs on the property when he rented it out to Plaintiffs and that Plaintiffs failed to create a question of fact in this regard.

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