should reasonably be expected to bear burden of insurance and fire damage); McGinnis ex rel. C.I.E. Service Corp. v. LaShelle, 166 Ill.App.3d 131, 116 Ill.Dec. 631, 519 N.E.2d 699 (1988) (looking to conduct of parties, court held no subrogation against commercial tenant absent express agreement that tenants were not coinsureds); New Hampshire Ins. Group v. Labombard, 155 Mich.App. 369, 399 N.W.2d 527 (1986) (construing additional lease provisions as evidencing parties' mutual expectation that landlord would insure); Rock Springs Realty, Inc. v. Waid, 392 S.W.2d 270 (Mo.1965) (ruling for tenant because lease provided for surrender in good condition, loss by fire excepted, and required tenant to comply with fire regulations); Community Credit Union v. Homelvig, 487 N.W.2d 602 (N.D.1992) (<HOLDING>); Monterey Corp. v. Hart, 216 Va. 843, 224
holding that a landlord may have a duty to exercise reasonable care for the safety of its tenants in common areas holding landlord and tenants obligations mutually dependent holding tenants leasing house by oral agreement were coinsureds both landlord and tenants had liability insurance holding landlord may recover from tenant for fire damage caused by tenants negligence regardless of existence of insurance holding that tenants had standing to bring fourth amendment claim where tenants were threatened with eviction unless they consented to allegedly unreasonable warrantless searches