Angel v. Black Band Consol. Coal Co – Case Brief Summary (West Virginia)

In Angel v. Black Band Consol. Coal Co., 96 W. Va. 47, 122 S.E. 274 (1924), the Court held that a former employee who remained in a house owned by his employer after his employment terminated was not a trespasser, but rather was a holdover tenant at will, because his employer knew he was on the premises and had treated him as such.

However, the Court said that when the employer terminated the tenancy at will by giving notice, the former employee then became a trespasser.