Soru

Passage:
Until the mid-twentieth century, American landlord-tenant law was dominated by the common law doctrine of *caveat lessee* (let the buyer beware), an agrarian-era principle rooted in the premise that a lease was primarily a conveyance of land. Under this traditional doctrine, landlords had no obligation to maintain leased premises, and tenants were strictly liable for rent regardless of the property's condition, unless the lease contained explicit covenants to the contrary. However, as the United States transitioned into a predominantly urban, industrial society, the agrarian model became increasingly incongruous with the realities of modern multi-family urban dwellings, where tenants lacked the specialized skills necessary to effectuate complex structural, electrical, or plumbing repairs.

The paradigm shift crystallized in the landmark 1970 decision *Javins v. First National Realty Corp.*, in which Judge J. Skelly Wright dismantled the archaic property-based framework. Wright argued that modern residential leases should be analyzed under contract law principles rather than traditional property law conveyances. Drawing a direct analogy to the implied warranties of fitness and merchantability codified in the Uniform Commercial Code for the sale of goods, the court established the "implied warranty of habitability." This warranty posited that residential leases inherently contain a non-waivable obligation for landlords to maintain premises in a habitable condition, measured by compliance with local housing codes.

Crucially, the *Javins* court explicitly rejected the landlords' assertion that housing code violations were merely administrative infractions punishable by municipal fines, instead elevating these codes to the status of implied contractual terms. Consequently, a landlord's failure to remedy substantial housing code violations constituted a material breach of contract, liberating the tenant from the reciprocal obligation to pay the full contracted rent. The court delineated several specific tenant remedies, including rent withholding, rent abatement proportional to the diminished value of the premises, and the right to unilaterally terminate the lease.

Subsequent jurisprudence and legislative codification across numerous jurisdictions rapidly expanded upon the *Javins* framework, though they frequently diverged on the precise mechanics of rent escrow requirements during litigation. For instance, while some courts mandated that tenants deposit the entirety of the withheld rent into a court-administered registry pending resolution of the dispute, others permitted tenants to retain the funds if the landlord's breach was deemed exceptionally egregious. Furthermore, while early economic critics contended that the implied warranty would perversely exacerbate urban blight by forcing landlords to abandon marginally profitable properties rather than incur exorbitant repair costs, empirical analyses in the subsequent decades largely refuted this dire prognosis. These studies demonstrated that the doctrine instead catalyzed the professionalization of urban property management, as institutional landlords absorbed the compliance costs through economies of scale.

Based on the explicit information provided in the passage, which of the following statements are true? (Select all that apply)