Klingbeil Management Group Co. v. Vito

In this negligence case, we consider whether a landlord is liable for injuries to a tenant caused by the criminal acts of a third party and, if not, whether a local dead-bolt ordinance provides the basis for landlord liability in this case.

In February 1981, appellee Barbara L. Vito was raped in her apartment in Arlington by an unknown assailant. Subsequently, she filed this law action against the manager and owners of the 1821-unit apartment complex, appellants Klingbeil Management Group Company, Buckingham Apartments, Ltd., K.G.I. Company, Miden Company, Frank Stavroif, Richard W. Foster,…