Varone v. Publix Super Markets, Inc.
Two people were shot and killed inside a Publix grocery store on June 10, 2021, and the co-personal representatives of their estates sued Publix for negligence. The trial court granted summary judgment finding no legal duty to protect against the criminal attack because no prior similar criminal acts had occurred at the store. The Fourth DCA affirmed in an extended opinion reaffirming that Relyea v. State remains good law — a premises owner must have actual or constructive knowledge of prior, similar criminal acts before a duty to protect arises — and holding that Publix's nationwide active-shooter training and general statistics of grocery-store gun violence did not establish site-specific foreseeability sufficient to create a legal duty.
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