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Keywords

plaintiffdefendantnegligenceliabilityappealsummary judgmentwillduty of care

plaintiffdefendantnegligencesummary judgmentwillduty of careappellee

Related Cases

Williams v. Utica College of Syracuse University, 453 F.3d 112, 210 Ed. Law Rep. 895

Facts

Hollie M. Williams, a student at Utica College, was assaulted in her dormitory room on October 26, 1999, by a masked assailant. At the time of the attack, the college had a security policy requiring that all outer doors to its residential halls be locked, with the exception of a breezeway entrance that was supposed to be monitored during office hours. Williams and her roommate left their door slightly ajar while preparing lunch, allowing the assailant to enter and assault them. The assailant was never identified, and Williams later filed a negligence suit against the college, claiming that its failure to provide adequate security led to her assault.

Nestled in upstate New York, Utica College had a student body (in 1999) of over 2000 students, 775 of whom lived in one of five on-campus dormitories. During her sophomore year, Williams shared a room on the second floor of North Hall, where, on October 26, 1999, she and her roommate—also a sophomore—were assaulted by a masked, unknown attacker.

Issue

The main legal issues were whether the college had a duty to protect Williams from the attack, whether the attack was foreseeable, and whether the college's security measures were adequate.

The District Court held that Utica College's duty as a landlord did not extend to the October 1999 assault on Williams because that particular type of attack was not foreseeable given the history of on-campus crime at Utica College.

Rule

Under New York law, a landlord has a duty to maintain their property in a safe condition and to minimize foreseeable dangers, including the criminal acts of third parties. A plaintiff must demonstrate that the defendant owed a duty of care, breached that duty, and that the breach caused the plaintiff's injuries.

In order to establish a prima facie case of negligence under that state's cases, a claimant must demonstrate that: “(1) the defendant owed the plaintiff a cognizable duty of care; (2) the defendant breached that duty; and (3) the plaintiff suffered damage as a proximate result of that breach.”

Analysis

The court analyzed the foreseeability of the attack and the adequacy of the college's security measures. It concluded that the college's duty did not extend to the circumstances of the assault because the type of attack was not foreseeable given the low history of violent crime on campus. Additionally, the court found that there was insufficient evidence to establish that the assailant was an intruder who gained access through a negligently maintained entrance, which is necessary to establish causation in premises liability cases.

The District Court's analysis of the foreseeability issue was flawed because it assumed that only actual prior crimes could put Utica College on notice of the risk of future crimes.

Conclusion

The Court of Appeals affirmed the District Court's grant of summary judgment in favor of Utica College, concluding that Williams failed to present sufficient evidence to establish that her assailant was an intruder and that the college's security measures were adequate.

Accordingly, there is insufficient evidence of cause-in-fact to go to a jury, the grant of summary judgment for the defendant by the District Court was proper, and we AFFIRM.

Who won?

Utica College prevailed in the case because the court found that the attack was not foreseeable and that Williams did not provide sufficient evidence to establish causation.

The District Court granted Appellees' request, dismissing Williams' suit for three separate reasons.

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