A California Appellate Court decided, in the case Garcia v. Holt (2016) 242 Cal.App 4th 600, that a landlord is not liable to the landscaper for injuries sustained after he stepped on a homemade bomb the tenant left in the yard. The Court noted that due to the landlord not having actual or constructive notice of the dangerous condition, the landlord never had the power, ability, or opportunity to remove the dangerous condition, and therefor not liable under a premises liability cause of action.
The outcome of this case may be obvious, but it is important for landlords to understand that knowing of a dangerous condition and not remedying it before an injury occurs can expose the landlord to liability. Had the landlord in the Garcia v. Holt case been on actual or even constructive notice of the dangerous condition, the landlord would have likely been found liable under a premises liability cause of action. More importantly to understand for tenants, however, is to not make bombs!