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.
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