Becker v. IRM Corporation: Strict Liability in Tort for Landlords

This Note will address several questions which are both old and new in tort law. How does the court apply a stream of commerce approach to strict products liability? What does it mean for a landlord to be in the business of leasing so that strict liability may be imposed for injuries caused by latent defects in residential units? What is a latent defect so that landlords may take necessary preventative steps before renting a unit? In addition, this Note will examine the policies for extending strict liability which have developed in California case law. This Note will show that the Becker decision has created a new definition of stream of commerce and in so doing has greatly increased the potential for the imposition of strict liability in other areas of the residential housing market