Does a landlord have an obligation to safeguard a tenant's personal property?

"New York", United States of America

The following excerpt is from Khan v. Pickens, 112 N.Y.S.3d 876 (Table), 62 Misc.3d 1209 (A) (N.Y. City Ct. 2019):

In addition to a landlord's obligation to safeguard a tenant's personal property, where a tenant demands the return of his or her property, as was done in this case, the landlord must permit the tenant to go on the premises and remove the personal property. "A conversion takes place when someone, intentionally and without authority, assumes or exercises control over personal property belonging to someone else, interfering with that person's right of possession." Colavito v. NY Organ Donor Network, Inc. , 8 NY3d 43 (2006). If a tenant's claim of conversion is established, the landlord would be responsible for the costs of the items that were not returned.

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