Satchwell v. LaQuinta Motor Inns, Inc.
1988 Fla. App. LEXIS 4841, 532 So. 2d 1348, 13 Fla. L. Weekly 2434 (1988)
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Rule of Law:
A business owner's duty to protect patrons from third-party criminal acts arises only when such acts are reasonably foreseeable. To establish foreseeability, a plaintiff must provide evidence that the owner had actual or constructive knowledge of a dangerous condition, which may include prior similar crimes, a high local crime rate, or peculiar security problems posed by the premises.
Facts:
- T. Erwin Satchwell, III, checked into a LaQuinta Motor Inn located adjacent to wooded and undeveloped property.
- Approximately two months prior to Satchwell's stay, a car was stolen from the inn's parking lot.
- The innkeeper had previously encountered vagrants sleeping in a trash can area on the perimeter of the premises.
- In the past, the inn had hired security guards during times of heavy business, but their purpose was to police unruly partying guests, not to protect against third-party criminal acts.
- On February 3, 1984, while carrying his bags into his room, Satchwell left the room door open behind him.
- Unknown assailants entered the room through the open door, where they attacked, beat, and robbed Satchwell.
Procedural Posture:
- T. Erwin Satchwell, III, filed a complaint alleging negligence against LaQuinta Motor Inns, Inc., in a Florida trial court.
- At trial, the judge excluded Satchwell's testimony concerning a prior car theft on the premises.
- At the close of Satchwell's case, LaQuinta moved for a directed verdict.
- The trial court granted the motion for a directed verdict in favor of LaQuinta.
- Satchwell, as the appellant, appealed the trial court's judgment to the District Court of Appeal of Florida, First District.
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Issue:
Does a motel have a legal duty to provide security against a violent criminal attack on a guest when the only significant prior criminal activity on its premises was a single, dissimilar car theft and occasional encounters with vagrants?
Opinions:
Majority - Per Curiam
No. A motel does not have a legal duty to provide security against a violent criminal attack where the evidence of foreseeability is insufficient to put the business on notice of such a risk. A proprietor's duty to protect invitees from criminal acts by third parties arises only when those acts are reasonably foreseeable. In this case, the single prior car theft was not substantially similar to the violent assault on Satchwell and was therefore insufficient, by itself, to make the subsequent attack foreseeable. Likewise, encounters with vagrants on the property's perimeter and the prior use of security guards for unrelated purposes did not establish that a violent assault was a foreseeable risk. The plaintiff failed to present evidence regarding industry standards, local crime rates, or peculiar security problems that would have placed the motel on notice that its guests were subject to an unreasonably high risk of criminal attack.
Analysis:
This decision reinforces the high evidentiary bar for plaintiffs in premises liability cases involving third-party criminal acts. It clarifies that foreseeability requires more than generalized knowledge that crime can happen; it demands specific evidence that the particular type of crime was a known or knowable risk. The court's emphasis on the dissimilarity between a property crime (car theft) and a violent crime (robbery/assault) narrows the scope of what constitutes a 'prior similar incident,' making it more difficult for plaintiffs to establish a duty without a pattern of nearly identical criminal acts on or near the premises.
