Dama Holding LLC v. Juan Guelmes
The Third DCA affirmed a $4 million jury verdict against a residential landlord whose tenant was shot four times by an unknown assailant, holding that the special landlord-tenant relationship creates a non-delegable duty to protect tenants from reasonably foreseeable third-party criminal conduct. The court also affirmed that foreseeability may be established by evidence of prior criminal activity in the surrounding neighborhood — not only on the leased premises.
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