Recently, the Pennsylvania Superior Court held that sellers of residential real estate are under no duty, pursuant to the Real Estate Seller Disclosure Law, 68 Pa.C.S. §7101 et seq. (“RSDL”), to disclose prior to a sale that a murder / suicide occurred on the property. The Court’s opinion in Milliken v. Jacono, 2012 PA Super 284, provides necessary clarity regarding what constitutes a “material defect” necessary to disclose to a buyer of residential real estate in Pennsylvania.
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