Who knows? We don't know enough facts. Did the landlord make a reasonable attempt to notify an emergency contact? Law enforcement is generally tasked with notifying next of kin, how long did the family wait? Was the tenant in default at or after the time of death? I think most people can agree it's "a dick move" to throw possessions in the garbage, but the landlord has plenty of defensive moves here. This is why the law is interesting -- there are so many gray areas with emotion getting in the way.