Zanders v. Lambert

In Zanders v. Lambert, 514 So. 2d 617 (La. Ct. App. 1987), cert. denied, 515 So. 2d 1109 (La. 1987), the Louisiana court determined that an apartment building owners' failure to comply with fire code requirements could not be introduced as evidence of the owners' negligence in a wrongful death suit brought by the survivors of tenants killed by the act of an arsonist. Id. at 617-19. Some of the fire code regulations cited by the plaintiffs did "not apply to the defendants' building." Id. at 620. Moreover, under the facts of that case, the "arsonist intended to set fire to an entire side of the apartment building . . . ." Id. at 619. The court reasoned: "It could reasonably be concluded that if there had been a second stairway, the arsonist would have set fire to that means of escape also." Id.