What is a landlord's liability for not installing fire alarms?

Question Details:

My daughter lived in her apartment for 5 weeks with no fire alarms in place; they were in the trunk of the landlord's car. A fire started while all were asleep but they all got out. However they lost everything except for the clothes on their backs. Can landlord be held responsible for anything that they lost? They did not have any renter's insurance edue to a high premium because there were no smoke alarms.

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