Last year we discussed a case where the Georgia Court of Appeals held that a residential lease between a landlord and tenant could be used to shorten the statute of limitations for filing a personal injury claim from two years to just one year. The plaintiff tenant subsequently asked the Supreme Court of Georgia to review that decision. The Supreme Court agreed to do so, and on October 21, it issued a decision reversing the Court of Appeals.
Langley v. MP Spring Lake, LLC
To briefly review the facts of this case, the plaintiff rented an apartment from the defendant. One day, the plaintiff fell in a common area of the apartment complex. She maintains her fall was the result of improper maintenance, specifically with respect to a portion of the curb where her food got caught. The plaintiff subsequently filed a personal injury lawsuit against the defendant.
In response to the lawsuit, the defendant argued that its lease with the plaintiff required her to bring any legal action arising under the lease within one year. The plaintiff actually filed her lawsuit just short of two years after the accident, which complied with Georgia’s statute of limitations for personal injury claims. The defendant maintained, however, that the lease effectively overruled and shortened the statute of limitations.
The Court of Appeals agreed with the defendant. It held the one-year limitations period of the lease applied to “any legal action” arising under said lease. This language was sufficient, in the Court’s view, to include personal injury actions.
The Georgia Supreme Court did not see it that way. Writing for the Court, Justice Charles J. Bethel said the phrase “any legal action” should not be “given its literal meaning,” but rather it was “intended to limit its application to lawsuits arising from the lease agreement” itself. And given the defendant drafted the lease, any ambiguity in the meaning had to be construed in favor of the plaintiff as the “non-drafter.”
Looking at the lease itself, Justice Bethel explained this was a fairly typical residential lease. In other words, it was a contract that created a landlord-tenant relationship. But the plaintiff’s accident was “not legally predicated” on this relationship. It was a premises liability claim that anyone could have brought had they fell on the defendant’s property.
So to the extent the lease purported to restrict the plaintiff’s ability to file a lawsuit arising from the landlord-tenant relationship, it was not “reasonable” to apply that same restriction to a personal injury claim. As Justice Bethel noted, to read the lease in that way would lead to some absurd legal outcomes: “It is difficult to believe, for example, that the parties intended the Limitation Provision to apply to tort claims resulting from a traffic accident miles away from the apartment complex between [the plaintiff’s] and the property manager’s vehicles, an intentional tort lawsuit against a property manager for punching a tenant, or a shareholder liability suit if [the plaintiff] happened to be a shareholder in [the defendant].”