What is the test for a commercial landlord to be able to claim damages from a tenant who is injured in a motor vehicle accident?

Such a landlord, the Becker court reasoned: (1) makes an implied representation in the lease that the premises are fit for use as a dwelling; (2) is in a much better position than the tenant "in the increasingly complex modern apartment buildings" to inspect for and repair latent defects, and (3) "by adjustment of price at the time he acquires the property, by rentals or by insurance is in a better position to bear the costs of injuries due to defects in the premises than the tenants." (Becker v. IRM Corp., supra, 38 Cal.3d 454, 464-465, 213 Cal.Rptr. 213, 698 P.2d 116.)