Martin v. Konstam

In Martin v. Konstam (1992), 62 Ohio Misc.2d 507, 602 N.E.2d 1273, the tenant's guests entered the elevator in the apartment building and were injured when the elevator malfunctioned. Id. at 508. The elevator was in the common areas of the building and under the control of the landlord. Id. The trial court held that the guests of the apartment tenant were business invitees of the landlord. Id. at 511.