An out-of-possession landlord is not liable for injuries caused by dangerous conditions on leased premises in the absence of a statute imposing liability, a contractual provision placing the duty to repair on the landlord, or a course of the landlord's conduct giving rise to a duty. When an out-of-possession landlord retains some control and has a contractual duty to make repairs to the leased premises, the question of liability will turn on whether the injury-producing condition fell within the landlord's contractual responsibilities.
N.G. v. DRF Mgt. Corp., NY Slip Op 00065 (2d Dep't January 10, 2024)
