Supreme Court of New Jersey

William H. Evers v. Annie T. Davis

April 24, 191486 N.J.L. 196

Summary

The Supreme Court of New Jersey reversed the lower court, holding that the proper remedy for the death caused by the lack of fire escapes was an action of negligence, not a statutory violation action, because the Tenement-House Act of 1904 provides only a public penalty and no private right of action.