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Keywords

damagesnegligenceappealtrial

damagesnegligenceappeal

Related Cases

Miller v. State, 62 N.Y.2d 506, 467 N.E.2d 493, 478 N.Y.S.2d 829, 19 Ed. Law Rep. 618

Facts

Madelyn Miller, a 19-year-old junior at SUNY Stony Brook, was attacked in her dormitory laundry room by an intruder wielding a knife. The assailant entered through an unlocked outer door, and despite previous reports of criminal activity in the dormitory, all entrances were left unlocked. Miller had previously complained about nonresidents loitering in the dormitory, and the trial court found that the State's failure to secure the dormitory was a breach of its duty to protect its tenants.

The claimant, Madelyn Miller, a 19-year-old junior at the State University of New York (SUNY) at Stony Brook, was confronted in the laundry room of her dormitory at approximately 6:00 a.m. on March 9, 1975, by a man wielding a large butcher knife.

Issue

Whether the State, as a landlord, could be held liable for negligence in failing to maintain security measures that led to the student's rape.

Rule

A student injured in a criminal assault in a State-operated college dormitory may recover damages against the State as a landlord if there is a reasonably foreseeable likelihood of criminal intrusion and the State negligently failed to maintain security measures.

When the State operates housing, it is held to the same duty as private landlords in the maintenance of physical security devices in the building itself.

Analysis

The court determined that the State's failure to lock the outer doors of the dormitory constituted a breach of its duty to maintain a safe environment for its tenants. The court emphasized that the State, when acting in its capacity as a landlord, is subject to the same standards of care as private landlords, which includes taking reasonable steps to prevent foreseeable criminal acts.

Thus, a student who is injured in a criminal assault in a State-operated college dormitory may recover damages against the State in its capacity as a landlord upon a showing that there was a reasonably foreseeable likelihood of criminal intrusion into the building, that the State negligently failed to keep the outer doors locked, and that the failure was a proximate cause of the injury.

Conclusion

The Court of Appeals reversed the Appellate Division's decision and remitted the case for further proceedings, affirming that the State could be liable for its negligence as a landlord.

Accordingly, the order of the Appellate Division should be reversed, and the case remitted to the Appellate Division, Second Department, for determination of the facts and issues not reached on the appeals to that court.

Who won?

Madelyn Miller prevailed in the case because the court found that the State's negligence in failing to secure the dormitory doors was a proximate cause of her injuries.

Claimant was found not to be contributorily negligent for being in the laundry room after sunrise on a Sunday morning.

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