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Home · Property Management · Latest News : Should’ve Seen This Coming? Landlord Sued for Failure to Warn
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A high-school teacher who says she was humiliated by students and peers over bite marks on her arms is suing her landlord over the culprits- bedbugs that invaded her apartment after she had lived there for a year.

The former tenant, who claims she can no longer go to bed at night without turning her room upside down hunting for bugs and needs to keep her arms covered even in the summer to hide scarring, filed suit against her former Baltimore-area landlord asking the court for a judgment in excess of $100,000.

Her attorney believes this to be the first case in Maryland concerning a landlord’s duty to warn of the dangers of bedbugs.  The theory of the case is based in negligence, more specifically premise liability, which outlines the duty owed by the owner of a property to those who are invited or licensed to use it.

The landlord in the case is denying it had any inkling that bed bugs were in the units, and once they were discovered, the pests were eradicated as quickly as possible.

If the tenant is successful, the case could impact the way landlords handle routine pest inspections.

For more, see Are You Screening Your Tenants for Bedbugs?

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  • Mike Hunter

    What is the accepted treatment for bedbugs? I have heard that putting linens in a dryer at hot setting works. What about treatment of the apartment?

  • Mary Ann

    This case is based on very thin ice. According to the article, the bedbugs appeared a YEAR after she lived in the apartment. It could be argued that SHE introduced the bugs. In this case, until notified by her that extermination was necessary, how would the landlord have known? Apparently they were not there when she moved in (I doubt the bugs would have waited a year to have a meal) – so where’s the negligence?


  • Shirley

    I can’t believe this. One thing that never occurred to me is that bed bugs could travel between units or lay dormant in an unfurnished apartment until someone else moves in… I thought they were transferred by people’s belongings coming in contact with a bed bug infested room such as a motel and then the belongings are taken home… regardless, I can’t believe that a landlord could be sued for negligence. If it were roaches or any other pest, I don’t think a negligence suit would be happening, it’s the widespread fear and panic people are in over bedbugs. Another reason I’m getting out of the landlord business. Selling some property and turning the rest over to a professional management company so as not to have to deal with things like this. Unfortunately these things run us smaller landlords out.

  • Kevin

    Landlords do not cause bedbugs, it is the Tenants that bring them, from hotels, movie theater, hospitals, schools, work, etc. The landlords should be in position to sue the tenants that bring in this problem into their property.


    I think we need a professional entomologist to chime in on this topic:
    Can bedbugs or their eggs be dormant for extended periods of time (with some insects, this is “yes”, but I’m not clear)?
    Do bed bugs inhabit anything other than personal property; i.e. walls, carpets, drapes, cracks, floorboards, cupboards, etc… (if so, then they may have indeed been there prior to her arrival)?

    Also, it can be just as easily argued that another tenant in another unit or guests could have introduced the pests, so suggesting that the lady did so inadvertently herself is the equivalent of speculation and will not be admissible.

    This should help focus on the landlords premise liability.

    What steps can the manager take to show inspection photos and video from the last move-out and upon her move-in inspections? Between these events, can the manager document any pest control, house cleaning and other measures via receipts from reputed service providers, that things were properly sanitized and cleaned? What about a history of maintenance and repairs? Complaints from adjacent units next door, below or above the tenement in question? City and county pest control agencies that track statistical trends in the area regarding bed bug reports and their waxing and waning over time? Bed bug activity relative to the seasons and climate (after all, a bad infestation might be the extension of a larger epidemic of them in a community and alleviate the landlord of liability).

    Good investigation is more than just blanket denials in court.

  • Joseph

    Just another unhappy tenant going after the landlord. Everyone wants to sue somebody for something. I say, kick her out on her ass as soon as you can.

  • Steve

    What about evidence that the bedbugs were there before the tenant move-in. Showing records of spraying for bugs before a tenant moves in and videos and photos of a clean unit should look good on the side of the landlord… right? And, to say that bedbugs miraculously appeared and infested the unit and the tenant suggests to me that the bedbugs were brought in by the new occupants. Especially if there have been no previous history of bedbugs. Now, I can understand if there had been a previous history of bedbugs with other tenants, and the landlord did not address the issue.. then there may be a case.

  • cb in austin

    Some pest control companies have specially trained dogs who can sniff out bedbugs (also termites) which I assume would be a cost effective way to do periodic inspections and provide proof of no infestation. Bedbugs are becoming a big problem in university dorms.

  • Anthony

    If this is a case of negligence than the woman is perfectly right for suing; this coming from someone who believes that people should do what they are supposed to when providing a service. The question is how much is her physical and mental suffering worth? And how is it effecting her job? I certanly wouldn’t want my child’s teacher passing bed bugs on to my kid and introducing them to my home! Is it worth $100,000? I don’t think so! That being said it is really hard to determine whether negligece played a role since bed bugs can go months without food, they are highly communicable, getting rid of them the right way is costly. I worked with this issue in the past and the biggest problem is a person’s fear of not really understanding what they are. They are nearly microscopic bugs that bite you while you’re asleep (usually) and they are hard to get rid of; they are the love child of roaches and mosiquitos.

  • We are a smaller management company for single family homes. Our lease agreement states that pests vary by season and location also that a tenant requested spraying must be made within the first 30 days. After that they are to use the phone directory to find and contract for spraying. (We do send the pest company when a home is vacant ).

    We also do two yearly inspections, taking pictures, writing a report that the tenant signs as well. Signs of any type of pest is noted and we will reinspect for correction, this heightens their quality of life and protects the property. We have found a home or two that had a large pest problem, charging this back to the security deposit, unless the infestation can be determined by the pest company to have a non-tenant contributed caused event.

  • bill

    As an owner of more than 100 units and majored in school in entomology I had a pest company for over 30 yrs until semi retired to my house business

    In all that time 30 yrs I don’t think we did 25 bed bug jobs albeit they are close to bat bugs found with bat infestation guano

    Since there was no real big problem the manufactures under epa rules stopped making any product that would not make up the cost of formulation and research. I remember hearing that a large manufacturer would spend over 25 million to bring a pest control product to market under epa rules I.E establishment number and product number . Consequently nothing was manufactured because there would be no sales to cover investment

    Then our country had an influx of immigrants that brought these insects with them from their home countries and the remedy in those countries was to spray with alcohal. Unfortunately the government has not allowed alcohal be used since it does not have both the epa Reg # nor establishment #

    The problem is that these creatures can come thru walls after the best efforts to control

    I attend entomology conferences yearly and many PHD’s speak on this topic and there is no firm solution to this ongoing problem to date

    Unfortunately , as with some lead paint lawsuits we are without insurance and vulnerable to the law firms that do this type of litigation

    It’s a terrible business to be in when you cannot insure yourself against unforseen problems and can be ruined overnight thru no fault of your own

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