In Garcia v. Holt, a court held the landlord was not liable for injuries as a result of the tenant maintaining explosives at the premises. In Garcia, Defendant landlords own a home, which they rented on a month-to-month basis. The landlords were not aware that the tenant made homemade explosives and stored them at the property. Plaintiff was hired by the defendants to maintain the landscaping at the property. While working outside, the plaintiff encountered explosive material, which exploded and injured him. The landscaper sued the landlords for premises liability. The landlords filed a motion for summary judgment asking the court to find that they had no duty to the landscaper given that they had no actual knowledge of the dangerous condition on the premises. The trial court agreed and granted the summary judgment in favor of the landlords. The court of appeals affirmed holding that the landlords had no duty to inspect the property for dangerous conditions.
This is an important decision for landlords. If landlords have no actual knowledge of a dangerous condition, they cannot be held liable for any injuries to third parties arising out of it.