Dowler v. Boczkowski

The opinion of the Court was delivered by

COLEMAN, J.

This appeal raises two issues: (1) whether the owner of a single-family rental property is under a duty to install one or more smoke detectors in the rented home when not required by law and (2) whether an owner who installs one smoke detector in such a home can be held liable for injuries caused by a fire when the breach of duty alleged is based on the placement of that smoke detector.

The trial court granted summary judgment dismissing the complaint as a matter of law. A divided Appellate Division reversed in an unpublished opinion. The…