In what circumstances will a landlord be found to be strictly liable in a tort action?

The role of strict liability in landlord-tenant relationships was further explored in Golden v. Conway (1976) 55 Cal.App.3d 948, 128 Cal.Rptr. 69. The plaintiff sued the landlord in strict liability after suffering damages in a fire caused by a wall heater installed by a contractor at the landlord's behest approximately one year before. The court permitted maintenance of the cause of action on the ground "that a lessor of real property who ... is engaged in the business of leasing apartments and appurtenant commercial premises, equips the premises with an appliance without knowing whether or not it is defective because of the manner in which it was manufactured or installed, and it proves to have defects which cause injury to persons or property when used in a normal manner, is strictly liable in tort." (Pp. 961-962, 128

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