Johnson v. Garrett
A patron shot at a strip club sued the property owner and his leasing entity (not the club operator or security contractor) for negligent security, and won a jury verdict premised on a non-delegable duty theory. The Sixth DCA reversed, holding the landlord and its managing entity lacked sufficient possession and control of the leased premises to owe a duty of care, and that U.S. Security Services Corp. v. Ramada Inn's non-delegable duty rule does not extend to an out-of-possession landlord who neither operated the business nor hired or supervised security.
Key facts
- A patron was shot at a strip club operated by a tenant; the patron sued the property owner and its leasing entity for negligent security.
- The jury returned a verdict for the plaintiff based on a non-delegable duty theory, finding the landlord liable despite not operating the business or hiring security.
- +2 more key facts with a free trial
Why it matters
This is a useful defense-side decision for out-of-possession commercial landlords facing negligent security claims, cabining the reach of the non-delegable duty doctrine from Ramada Inn. Counsel can cite it for the… — full analysis with a trial
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