with whom CARPENETI, Justice, joins, dissenting in part.
I respectfully dissent from the court's decision to affirm the trial court's directed verdict dismissing Richard Steve Helfrich's statutory retaliation claim under Alaska's Uniform Residential Landlord and Tenant Act.1
One of the purposes and policies underlying the Act is to encourage landlords to properly maintain rental premises.2 Under AS 34.03.100 a landlord is required to "make all repairs and do whatever is necessary to put and keep the premises in a fit and habitable condition"3 and to "keep all common areas of the premises in a clean and safe condition." 4 "Premises" is defined broadly to include a dwelling unit and related strue-tures, as well as "grounds, areas, and facilities held out for the use of tenants generally." 5
Prior to the Act landlords had some immunity from liability for personal injuries caused by dangerous conditions of a rental premises.6 But in Newton v. Magill we held that because of the legislature's adoption of the Act7 and our own previous approval of "the trend toward a more general duty of care for landowners," 8 the common law rules of landlord immunity were in conflict with modern public policy.9 We held that landlords are not strictly liable as insurers of the fitness of the rental premises, but rather have a "duty to use reasonable care to discover and remedy conditions which present an unreasonable risk of harm under the circumstances." *56310 We reached that holding:
because it would be inconsistent with a landlord's continuing duty to repair premises imposed under the [Act] to exempt from tort liability a landlord who fails in this duty. The legislature by adopting the [Act] has accepted the policy reasons on which the warranty of habitability is based. These are the need for safe and adequate housing, recognition of the inability of many tenants to make repairs, and of their financial disincentives for doing so, since the value of permanent repairs will not be fully realized by a short-term occupant.[11]
The Act provides some protections to a tenant who complains about the condition of the rental premises. A landlord "may not retaliate ... by bringing or threatening to bring" eviction proceedings "after the tenant has complained to the landlord of a violation of AS 34.03.100."12 For an example with some relevance to this case, a landlord should be statutorily prohibited from giving a tenant an eviction notice in retaliation for the tenant's complaint of an unsafe accumulation of ice on a common area pathway outside a fire-door exit of the tenant's apartment building. In Vinson v. Homilton we stated that the anti-retaliation provisions of AS 84.08.8310 reflect a public policy of encouraging tenants to assert their rights under the Act without fear of eviction.13
A tenant has two separate, but cumulative, statutory remedies for a landlord's failure to comply with AS 34.03.100.14 Faced with "a noncompliance with AS 34.08.100 materially affecting health and safety," the tenant may give notice that the tenancy will terminate unless the breach is remedied.15 If the landlord does not remedy the breach "by repairs or the payment of damages or otherwise," the tenancy terminates pursuant to the notice and the tenant may vacate the premises without further rental obligations.16 In addition a tenant "may recover damages and obtain injunctive relief for any noncompliance by the landlord" with AS 34.03.100.17
The Act also provides some protections for the assertion of these rights and remedies. A landlord "may not retaliate ... by bringing or threatening to bring" eviction proceedings "after the tenant has ... sought to enforce rights and remedies granted the tenant under [the Act]."18 If in the earlier example the tenant actually sued the landlord over the unsafe ice accumulations, the landlord should be statutorily prohibited from giving the tenant an eviction notice in retaliation for the attempt to seek compensation for damages caused by, or injunctive relief to ameliorate, the unsafe condition of the premises.19
In this case Helfrich asserted a claim that Valdez Motel Corporation illegally retaliated against him with an eviction notice after his attorney made contact to seek the payment of medical bills and related damages incurred as a result of Valdez Motel's alleged failure to maintain a common area in a safe condition. The trial court found that Helfrich was a tenant of Valdez Motel and that his tenancy was covered by the Act, and Valdez Motel does not contest that finding.
*564In his letter to Valdez Motel, Helfrich's attorney stated that on March 21, 2005, Helf-rich slipped and fell on an ice accumulation "on the path outside the back (fire-exit) door," which he noted to be "a well-used access route [that] has been the scene of other accidental falls during the past winter." He advised Valdez Motel that Helfrich's medical bills were in excess of $40,000. He asked Valdez Motel to assume its "rightful responsibility" and make every effort to obtain from its insurer "full coverage for all expenses and damages that Mr. Helfrich has suffered."
After receipt of the letter Valdez Motel's representative placed what Valdez Motel later admitted was intended to be an eviction notice on Helfrich's room door, stating in part: "I really don't appreciate getting a threatening letter from an attorney. I think ... it is best you move out as fast as you can. I recommend perhaps moving in with whoever gave you such back stabbing [sic ] advice. If no one, I guess it is time for a tent (on someone else's property)." Helfrich vacated the premises immediately after finding the eviction notice.
The trial court granted Valdez Motel's motion for a directed verdict on Helfrich's retaliation claim at the close of his case-in-chief. The trial court conceded Helfrich had presented evidence that he sought to enforce rights, but concluded the rights Helfrich was attempting to enforee were not rights related to his tenancy. The trial court stated that a negligence action stands on its own without any connection to a landlord-tenant relationship and that seeking damages for personal injuries caused by unsafe conditions on the landlord's property is not encompassed within AS 34.08.160(b).
By affirming the trial court's decision, the court ignores or repudiates Newton v. Magill and Vinson v. Hamilton and the policies underlying those cases, and also ignores the legislature's statement of the Act's purposes and policies and its mandate that the Act be liberally construed to promote those purposes and policies.
The court proceeds as if a landlord's tort duties to tenants rest only on the evolution of the common law duties of property owners and have nothing whatsoever to do with the Act and its modification of the tenancy relationship between the landlord and tenant. Newton v. Magill dispels that notion: a landlord's tort duties to tenants are what they are today because of the Act.20 The landlord's duty under AS 34.08.100 is the tort duty of reasonable care under all of the relevant cireumstances.21 Failure to comply with that duty is both a tort and a breach of AS 34.08.100.
The court ably details the reasons this interpretation of the Act would promote its purposes and policies, but instead adopts a "narrower reading" of the Act. This narrow reading of the Act is in direct conflict with: (1) the legislature's mandate for liberal application of the Act; (2) the liberal effect given the Act in Newton v. Magill; and (3) Vinson v. Hamilton's liberal interpretation and construction of the public policy underlying the anti-retaliation provisions of AS 34.08.310. From a practical standpoint, the court's narrow reading of the Act produces a perverse framework of anti-retaliation protection.
The tenant who complains about unsafe conditions of a stairway cannot be threatened with eviction for her complaints-but when her child is injured on the unsafe stairway and she seeks to have the landlord take responsibility and pay the child's medical bills, she can be evicted with impunity. The tenant who complains about plumbing problems eannot be threatened with eviction for his complaints-but when the plumbing explodes, raw sewage covers his basement apartment, and he seeks to have the landlord take responsibility and pay for cleaning or replacing his personal property, or for precautionary inoculations against disease, he can be evicted with impunity. This should not be the law of Alaska.
We should promote the statutory purpose of encouraging landlords to maintain rental premises. We should promote the public policy of encouraging tenants to assert their rights under the Act without fear of eviction *565threats. We should acknowledge Newton v. Magill and liberally construe the phrase "damages ... for any noncompliance by the landlord with ... AS 34.08.100," to include tort and contract damages.22 A liberal interpretation of AS 34.08.100(a) and (b) cannot lead to the result the court reaches today.23
The court seems to fear that acknowledging a retaliation claim under Helfrich's cireumstances is an acknowledgment of some kind of strict liability standard accompanying the landlord's repair and maintenance obligations under AS 34.03.1100. But we expressly rejected that possibility in Newton v. Magill.24 Acknowledging the validity of Helfrich's claim simply means that whether a tenant is complaining about-or suing about-the landlord's failure to maintain the rental premises as required by AS 34.08.100, the landlord cannot threaten eviction of the tenant in retaliation for the tenant's assertion of rights under AS 34.08.160 and AS 34.03.100.25
I would reverse the trial court's directed verdict on Helfrich's statutory retaliation claim and remand for trial of that claim.
. AS 34.03.
. AS 34.03.010(b)(2). The legislature has directed that the Act "be liberally construed and applied to promote its underlying purposes and policies." AS 34.03.010(a).
. AS 34.03.100(a)(1).
. AS 34.03.100(a)(2).
. AS 34.03.360(14).
. Newton v. Magill, 872 P.2d 1213, 1216 (Alaska 1994) (identifying Alaska's common law rules of landlord liability).
. Id. at 1214, 1217 (citing AS 34.03.1100).
. Id. at 1217 (citing Webb v. City & Borough of Sitka, 561 P.2d 731, 733 (Alaska 1977)).
. Id. at 1217-18.
. Id. at 1218.
. Id. at 1217.
. AS 34.03.310(a)(1). "Complained" is not defined in the Act, but the relevant Webster's definition of "complain" is "to express discontent [or] dissatisfaction." Wesstea's Teo New Inter wmationat Dictionary 464 (2002). See AS 01.10.040(a) (instructing that "[wJords and phrases shall be construed according to the rules of grammar and according to their common and approved usage").
. 854 P.2d 733, 736 (Alaska 1993).
. AS 34.03.160(a)-(c).
. AS 34.03.160(a).
. Id. (emphasis added).
. AS 34.03.160(b)-(c) (emphasis added).
. AS 34.03.310(a).
. The statutory remedy afforded a victim of illegal retaliation is limited. Under AS 34.03.310(b) a tenant may assert retaliation as a defense to an eviction action and is entitled to the same statutory remedies afforded to a tenant expressly or constructively evicted in violation of law; in the latter event "the tenant may recover possession or terminate the rental agreement and, in either case, recover an amount not to exceed one and one-half times the actual damages." AS 34.03.210.
. Newton, 872 P.2d at 1217-18.
. Id. at 1218.
. The Act does not define "damages," nor does the Act expressly limit "damages," but common usage of the term certainly favors Helfrich and supports my view of Newton v. Magill Webster's defines "damages" as compensation "imposed by law for a wrong or injury caused by a violation of a legal right." Wesster's Third New International Dictionary 571 (2002). Black's defines "damages" as monetary "compensation for loss or injury." Buack's Law Dictionary 416 (8th ed.2004).
. The court also seems to hold that unless a tenant expressly refers to a specific provision of the Act in a communication to a landlord, the communication will not be interpreted to refer to rights under the Act at all. This is form over substance and clearly inconsistent with the purposes and policies of the Act, especially the anti-retaliation provisions of AS 34.03.310. The relevant inquiry should be whether the rights asserted by the tenant are protected by the Act, not whether the tenant is conscious of the specifics of the Act. The fact that Helfrich's attorney sought medical bill reimbursement and damages for injuries alleged from an unsafe condition on the rental premises is sufficient to invoke the protections of AS 34.03.100(b) and AS 34.03.310(a).
. 872 P.2d at 1218.
. I also note my view that a demand or suit for compensation made in the context of a continuing tenancy can be easily construed as an expression of discontent or dissatisfaction with the landlord's performance of obligations under AS 34.03.100, i.e., a complaint protected from retaliation by AS 34.03.310. See Newton, 872 P.2d at 1216.