Staley v. Bouril

ZAPPALA, Justice,

dissenting.

Because I find that the implied warranty of habitability is an inappropriate basis for the relief being sought by the Tenants, I respectfully dissent. The rationale we applied in adopting the implied warranty of habitability in Pugh v. Holmes, 486 Pa. 272, 405 A.2d 897 (1979), does not support the majority’s decision to expand the implied warranty to include lots in mobile home parks. Also, because the Tenants could proceed under a simple breach of contract claim, it is neither necessary nor prudent for us to recognize a cause of action based on the amorphous concept of a “limited” implied warranty of habitability, which, as the majority recognizes, “leave[s] it to the trial court to determine the scope of the Landlord’s limited implied warranty of habitability; the extent, if any, to which the Landlord breached the warranty; *119whether the Tenants gave the Landlord adequate notice of the problems; and the remedies, if any, to which the Tenants are entitled.” Majority Opinion at 285 n. 2. A traditional breach of contract claim would resolve the dispute expeditiously without implicating such a host of additional issues.

As the majority recognizes, our “primary rationale” for adopting the implied warranty of habitability in Pugh was that “the modern tenant is not interested in land, but rather bargains for a dwelling house suitable for habitation.” Id. at 284 (quoting Pugh, at 282, 405 A.2d at 902). My reason for concluding that this rationale does not support the expansion of the implied warranty to include land leased to mobile home owners can hardly be articulated any clearer than through the majority’s very own words: “Tenants’ lease is intended primarily to convey an interest in a plot of land, albeit with some improvements, and has nothing to do with the dwelling structure that sits on top of it.” Majority Op. at 285 (emphasis added).

The Tenants’ injuries can be redressed in an action alleging that the Lessor breached its contractual duty to provide the Tenants with the accommodations necessary to adequately maintain their mobile homes on the land that they were leasing. We need not acknowledge a novel basis for recovery such as a “limited” implied warranty of habitability to compensate for the Tenants’ failure to pursue such a claim. As Superior Court noted, “the implied warranty of habitability recognizes that ‘the modern tenant is not interested in land, but rather bargains for a dwelling house suitable for habitation .... In this case, land, not housing, was the focus of the parties’ bargains.” Superior Court Memorandum at 4-5 (quoting Pugh, at 282, 405 A.2d at 901-902). The only dwellings relevant to this suit are those that were brought by the individual Tenants themselves, and were placed on the plots of land that are the subject matter of the contracts between the Landlord and each individual Tenant. Thus, I would affirm the orders of the lower courts.

CASTILLE, J., joins in the dissenting opinion.