Matthews v. Amberwood Associates Ltd. Partnership, Inc.
Court of Appeals of Maryland
719 A.2d 119 (1998)
Shelley Morton kept her boyfriend's pit bull in her apartment despite a lease provision prohibiting pets, and the dog, while calm around Morton, growled and acted vicious when she was away, generating multiple reports of dangerous encounters that management ignored without ever evicting her. While Morton was away, the dog attacked and killed the 16-month-old son of her visiting friend Shanita Matthews (plaintiff), who was unable to free the child from its jaws; Matthews sued the apartment owner and management company (defendants), and a jury awarded over $5 million, but the appellate court reversed, finding no duty owed to a tenant's social guest. Matthews appealed, arguing the landlord retained control over a known dangerous condition by allowing the vicious pit bull to remain despite the no-pets clause.
Whether a landlord who fails to evict a tenant with a dangerous animal, despite knowledge of the animal's dangerous propensities, is liable for injuries that animal inflicts on others on the premises.