Does anyone know if these tenants were covered by any rules preventing the landlord from not renewing their lease? If not, the landlord could always choose to not renew their lease the next year, install the smart locks, and then lease out the apartments to tenants who have explicitly acknowledged and approved of the smart locks.
I wonder if the courts would still try to enforce a no-smart-locks policy in that case. If they did, it would set a major precedent against landlords being able to customize their own homes and renting it out only to tenants who are okay with it.