• NY Apartment Law
  • Fair & Affordable Housing
  • Commercial Lease Law
  • Guidebooks
  • Log In
  • Log Out
  • My Account
  • Subscribe
  • NY Apartment Law
  • New York Apartment Law Insider
  • New York Landlord V. Tenant
  • Co-Op & Condo Case Law Digest
  • New York Rent Regulation Checklist, Fourth Edition
  • 2025 New York City Apartment Management Checklist
  • Fair & Affordable Housing
  • Fair Housing Coach
  • Assisted Housing Management Insider
  • Tax Credit Housing Management Insider
  • Fair Housing Boot Camp. Basic Training For New Hires
  • Commercial Lease Law
  • Commercial Lease Law Insider
  • Best Commercial Lease Clauses, 17/e
  • Best Commercial Lease Clauses: Tenant's Edition
  • Best Commercial Lease Clauses, 17/e
  • Best Commercial Lease Clauses, 17/e
May 19, 2025
We use cookies to provide you with a better experience. By continuing to browse the site you are agreeing to our use of cookies in accordance with our Cookie Policy.
The Habitat Group Logo
  • NY Apartment Law
    • New York Apartment Law Insider
    • New York Landlord V. Tenant
    • Co-Op & Condo Case Law Digest
    • New York Rent Regulation Checklist, Fourth Edition
    • 2025 New York City Apartment Management Checklist
  • Fair & Affordable Housing
    • Fair Housing Coach
    • Assisted Housing Management Insider
    • Tax Credit Housing Management Insider
    • Fair Housing Boot Camp. Basic Training For New Hires
  • Commercial Lease Law
    • Commercial Lease Law Insider
    • Best Commercial Lease Clauses, 17/e
      • Best Commercial Lease Clauses, 17/e
    • Best Commercial Lease Clauses: Tenant's Edition
  • Guidebooks
  • May 19, 2025
  • Log In
  • Log Out
  • My Account
  • Subscribe
  • May 19, 2025
The Habitat Group Logo
May 18, 2025
  • Log In
  • Log Out
  • My Account
Home » Limited Right to Re-Enter for Repairs Not Enough to Prove Premises Liability
Landlord Wins

Limited Right to Re-Enter for Repairs Not Enough to Prove Premises Liability

Mar 21, 2025
Glenn S. Demby

What Happened: A business visitor who slipped on ice in the parking lot of a commercial building leased to Amazon sued the landlord for negligence in failing to ensure the lot was properly plowed. The defendant denied owing the visitor a duty of care because it leased the entire property to Amazon and thus didn’t have possession or control over the area where the accident occurred. The visitor disputed the claim, noting that the lease gave the landlord the right to reenter the property to make repairs, upon providing 10 days’ written notice to Amazon.   

Ruling: The Connecticut court ruled that the visitor didn’t have a legally valid claim against the landlord and dismissed the case without a trial. 

Reasoning: As in most states, the general rule of premises liability in Connecticut is that landlords owe a duty of reasonable care only for the parts of the property over which they retain control. The specific terms of the lease determine whether the landlord or tenant has control. 

The landlord in this case leased 100 percent of the premises to Amazon, as exhibited by the lease language and attached map. The lease also expressly made Amazon responsible for snow and ice removal for all parts of the premises except the roof. 

But the visitor’s attorney came to court prepared, citing a case where a landlord who assigned the tenant responsibility for keeping a sidewalk in good repair was still liable to a plaintiff who tripped over the sidewalk. Unimpressed, the court noted that there was a key difference in that other case—namely, the fact that the landlord reserved the right to change the sidewalk arrangement with the tenant at any time and for any reason. There was no such similar language in the Amazon lease regarding the parking lot. And the landlord’s limited right to reenter the premises to make repairs wasn’t nearly enough to show control for premises liability purposes.

  • Colemen v. Donnelly Indus., 2025 Conn. Super. LEXIS 337, 2025 WL 602651

 

Owner Wins
    • Related Articles

      Disruption of Power Supply Not Enough to Prove Constructive Eviction

      "Out-of-Possession Landlord” Not Obligated to Make Repairs, Maintain Premises

      Don't Limit Your Right to Enter Tenant's Space

    • Related Products

      Special Report: How to Benefit from HUD’s Service Coordinators Program (from the Editors of Assisted Housing Management Insider)

    • Related Events

      Submit annual water and energy benchmarking data to the city.

      Submit Annual Drinking Water Storage Tank Inspection Results to DOHMH.

      Deliver Fire & Emergency Safety Plan to building employees and current occupants.

    Glenn demby headshot
    Glenn Demby

    Not Specifying Base Rent Amount May Render Lease Invalid & Unenforceable

    More from this author
    • Publications
      • Assisted Housing Management Insider
      • Commercial Lease Law Insider
      • Co-op & Condo Case Law Tracker Digest
      • Fair Housing Coach
      • New York Apartment Law Insider
      • New York Landlord v. Tenant
      • Tax Credit Housing Management Insider
    • Additional Links
      • Contact Us
      • Advertise
      • Group Subscriptions
      • Privacy Policy
    • Boards of Advisors
      • Assisted Housing Management Insider
      • Commercial Lease Law Insider
      • Fair Housing Coach
      • New York Apartment Law Insider
      • Tax Credit Housing Management Insider
    ©2025. All Rights Reserved. Content: The Habitat Group. CMS, Hosting & Web Development: ePublishing
    The Habitat Group Logo
    • NY Apartment Law
      • New York Apartment Law Insider
      • New York Landlord V. Tenant
      • Co-Op & Condo Case Law Digest
      • New York Rent Regulation Checklist, Fourth Edition
      • 2025 New York City Apartment Management Checklist
    • Fair & Affordable Housing
      • Fair Housing Coach
      • Assisted Housing Management Insider
      • Tax Credit Housing Management Insider
      • Fair Housing Boot Camp. Basic Training For New Hires
    • Commercial Lease Law
      • Commercial Lease Law Insider
      • Best Commercial Lease Clauses, 17/e
        • Best Commercial Lease Clauses, 17/e
      • Best Commercial Lease Clauses: Tenant's Edition
    • Guidebooks
    • May 19, 2025
    • Log In
    • Log Out
    • My Account
    • Subscribe
    • May 19, 2025
    The Habitat Group Logo
    May 18, 2025
    • Log In
    • Log Out
    • My Account