439 F.2d 477 (D.C. Cir. 1970)

One-Sentence Takeaway: Landlord was under a duty to protect the tenants from criminal acts of third-parties on the premises where the landlord had notice of repeated criminal assaults and robberies, had notice that these crimes occurred in the portion of the premises exclusively within his control, had every reason to expect like crimes to happen again, and had the exclusive power to take preventative action.

Summary: Plaintiff was a tenant in Defendant’s apartment building.  She was assaulted and robbed in the hallway of the apartment building and she sued Defendant for failure to take proper measures to protect her.  The issue was whether Defendant owed a duty to Plaintiff to protect her from criminal conduct of third parties.

The United States Court of Appeals for the District of Columbia Circuit held that Defendant was liable for injuries to Plaintiff caused by an intruder into Defendant’s apartment building. The Court found that the landlord had a duty to secure the building against intrusion by strangers, reasoning that criminal acts by third parties were reasonably foreseeable because of the increasing number of assaults, larcenies, and robberies that had been perpetrated recently against the tenants. The Court indicated that the landlord was the only party who had the power to provide the necessary protection.

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