## Blind judgment: location-j2 (French furnished main-residence lease, landlord side, October 2026)

**Tool notes.**
- The Alpaca Law tools did not work (error: "No claude.ai OAuth token available"), and Chrome was not connected.
- Légifrance blocked automated access (HTTP 403, then a Cloudflare check). Statute wording was therefore checked through secondary sources.
- Case law was checked on Juricaf, a free database of French court decisions, and on Judilibre, the Cour de cassation's search engine. Judilibre showed a CAPTCHA partway through. I stopped querying it rather than try to get past the CAPTCHA, so a few appellate citations were checked for existence only, or not checked at all.
- In total I checked more than 8 authorities per document.

### Strongest authorities for the central points
1. **Penalties and automatic termination:** loi 89-462, art. 4 i) and g), and art. 24 I as amended by loi 2023-668 (six weeks after a payment demand, and the termination clause is now mandatory). Cass. 3e civ., 22 Nov. 1995, n° 94-11.971 is the older contrary case: it treated a contractual late-payment penalty as valid. The words "ou des pénalités" were later added to art. 4 i). Recent appeal decisions strike 10 % late-payment surcharges (CA Rouen, 14 March 2024, RG 23/02623, verified).
2. **Landlord access and visits:**
   - art. 6 b) (quiet enjoyment) and art. 226-4 Code pénal (penalty raised to 3 years and €45,000 by the 2023 law);
   - Cass. 3e civ., 25 Feb. 2004, n° 02-18.081: a landlord who enters without permission breaches the tenant's privacy;
   - Cass. crim., 9 Nov. 1994, n° 94-81.505: an owner who changed the locks was convicted of violation de domicile;
   - CA Versailles, 26 Jan. 2023, RG 22/03632: no legal duty for the tenant to let the landlord in to inspect.
3. **Guests and occupancy limit:**
   - art. 4 n) is confirmed: it is cited as "4- n" in the appeal grounds of the 2010 judgment below;
   - Cass. 3e civ., 6 March 1996, n° 93-11.113: under art. 8 ECHR, a lease cannot stop the tenant from housing close relatives;
   - Cass. 3e civ., 10 March 2010, n° 09-10.412: a clause banning lending the flat to a third party is valid.
4. **Animals, insurance, rent, charges and deposit:**
   - animals: art. 10 of loi 70-598;
   - insurance: art. 4 b) and art. 7 g);
   - rent: art. 25-9, with art. 17-1 I and III and art. 17-2. I confirmed through the 2015 "loi Macron" amendment n° 2316 that art. 17-2 applies to furnished lets, with increases above 10 % phased in by thirds;
   - charges and deposit: art. 25-10 (flat-rate charges), art. 25-6 and art. 22 (deposit);
   - Cass. 3e civ., 16 Nov. 2023, n° 22-19.422: an exit inventory drawn up by the landlord alone does not prove damage.

### Document A
- All statute citations are accurate and current. This includes art. 4 b, c, f, g, i and p, art. 7 g (insuring on the tenant's behalf means giving up the termination clause for lack of insurance), art. 24 I, II, III and V after the 2023 law, art. 25-6 to 25-10, art. 3 (last rent of the previous tenant), decree 2015-981 and art. 226-4 at its 2023 penalty level.
- Case law is thin: only Cass. 6 March 1996, which is correctly used. It misses the directly relevant art. 4 n) and Cass. 25 Feb. 2004.
- The strategy serves the client well:
  - the payment demand can be served from the day after the due date;
  - insurer Assur'Logis is offered, not imposed, and is the fallback under art. 7 g;
  - two inspection visits a year by appointment, with the keys usable only in an emergency;
  - a limit of 4 habitual occupants that expressly allows hosting relatives (creative, and harmless if a court strikes it);
  - the smoking ban is kept, together with liability for smoke damage;
  - the flat-rate charge can be revised yearly;
  - the art. 25-8 I right to propose new terms at renewal.
- Small gaps:
  - it never ties the tenant's breaches to a landlord's notice for a legitimate and serious reason at renewal;
  - it misses the art. 17-2 rent revaluation for under-rented flats;
  - it cites art. 17-1 II for a rent increase after improvement works, where the furnished-let provision is art. 25-9.

### Document B
- Its sources are the richest set, and the ones I checked are accurate:
  - Cass. 25 Feb. 2004, Crim. 9 Nov. 1994 and Cass. 16 Nov. 2023 match what B says they hold;
  - B correctly explains why Cass. 1995 is superseded;
  - CA Rouen 14 March 2024, CA Montpellier 5 July 2022 (smoke damage in a furnished flat) and CA Versailles 26 Jan. 2023 match B's description;
  - CA Paris 28 May 2026 (24/03353), 19 Sept. 2024 (22/07770), 13 Nov. 2025 (23/08039) and 8 April 2025 (22/19656), plus CA Aix 22 May 2025 (22/14339), exist;
  - art. 4 n), art. 17-1 III, art. 17-2 via art. 25-9 with phasing by thirds, and art. 25-10 2° are all correct.
- Possible flaw: CA Lyon, 18 Oct. 2023 (20/06416) appears to concern a landlord's notice for a legitimate and serious reason, not a court-ordered termination as B presents it. I could not read the full text.
- Not checked because of the CAPTCHA: CA Douai 11 Dec. 2025, CA Caen 4 June 2026, CA Amiens 21 Nov. 2023, CA Nîmes 3 April 2025, CA Rouen 8 Feb. 2024 and CA Douai 16 Jan. 2025.
- Best levers for the client: lets the landlord refuse renewal over the tenant's breaches (art. 25-8 I), the art. 17-2 revaluation, the works increase, the "si bon semble au bailleur" wording (the landlord chooses whether to invoke termination), and an insurance carve-out in the termination clause.
- Weak move: "commandement dès 15 jours de retard". The law lets the landlord serve the demand immediately, and this wording can be read as a self-imposed wait. B also correctly rejects any numeric cap on people sleeping in the flat (art. 4 n).
- Counter-arguments are best anticipated here: the old Cass. 1995 case, the F/G rent freeze, the one-sided exit inventory, and the uncertain smoking ban.

### Document C
- The core statutes are correct: art. 4 b, g, i and n, art. 24 (six weeks), art. 25-6, 25-7 and 25-10, and loi 1970 art. 10.
- Several authorities are misused:
  - Cass. 3e civ., 14 Jan. 2016, n° 14-24.681 concerns an upward-only indexation clause in a commercial lease;
  - Cass. 10 March 2010 is cited as protecting the hosting of "tiers", but it actually upheld a clause banning lending the flat to a third party;
  - CA Paris, 26 Oct. 2017 (15/17695) does not rule on art. 10 of the 1970 law;
  - Cons. const. 2014-691 DC is cited for the protective public-order nature of the lease rules, which it does not establish;
  - the F/G rent freeze is attributed to art. 6 instead of art. 17-1 III;
  - interest on late rent is attributed to art. 24 instead of art. 1231-6 C. civ.
- It relies heavily on first-instance judgments (TJ). TJ Bordeaux 17 July 2026 and TJ Saint-Pierre 17 Aug. 2026 exist but are generic.
- On strategy, it wrongly declares the smoking ban illegal outright and drops it. It does not use the art. 7 g route to Assur'Logis, does not revise the flat-rate charge, offers only one visit a year, and reasons thinly with almost no counter-arguments.

### Scores

| Doc | Sources | Law in force | Strategy | Correct conclusion | Arguments | Total /25 |
|---|---|---|---|---|---|---|
| A | 4 | 5 | 5 | 5 | 4 | 23 |
| B | 5 | 5 | 4 | 5 | 5 | 24 |
| C | 2 | 3 | 3 | 3 | 2 | 13 |

### Winner: B (narrowly over A)
B and A reach the same correct answers on all nine objectives and both rewrite the lease into lawful equivalents. B backs its points with the most relevant verified authorities: the specific art. 4 n), Cass. 2004 on landlord entry, Cass. 2023 on exit inventories, and appeal decisions on penalties, smoke damage and access. It also answers the main counter-argument, the old Cass. 1995 penalty case. A's drafting is slightly more client-protective on the payment demand (from the next day rather than after 15 days), but its case-law support is thin and it misses the art. 25-8 non-renewal lever and art. 17-2. C is correct on the basics but misuses several authorities and gives up the smoking clause without need.