One resident of a boarding house killed another resident of the boarding house. The estate of the decedent brought a wrongful death and survival action against the landlord based on two theories: (1) a violation of the Rooming and Boarding House Act of 1979, and (2) common law negligence. The thrust of both causes of action was that the property manager failed to conduct a background check on the killer. The Appellate Division found no such obligation in the Rooming and Boarding House Act, and further found that it would be contrary to public policy to force any landlord to conduct such a search.
