Negligence – Duty of Landlord Toward his Own Social Guest Injured on a Common Stairway

Defendant was co-owner of an apartment house and occupied one of the apartments. Plaintiff, his invited social guest, was injured while descending the common stairway because of defendant’s negligence in failing to provide adequate lighting. A directed verdict for the defendant was affirmed by the appellate division on the ground that plaintiff as a social guest of the landowner was only a licensee. On appeal to the supreme court, held, reversed, three judges dissenting. A social guest of the landlord is an invitee while on the common stairway and therefore may recover for injuries sustained due to negligent maintenance of the premises. Taneian v. Meghrigian, 15 N.J. 267, 104 A. (2d) 689 (1954).