Doe v. Dominion Bank of Washington
United States Court of Appeals for the District of Columbia
963 F.2d 1552 (1992)
Jane Doe (plaintiff) worked in a commercial building where Dominion Bank (defendant) held the master lease and had let many leases expire, leaving much of the building vacant and largely unsecured. An intruder abducted Doe from an elevator into a vacant office and raped and robbed her. At trial, Doe presented evidence of the building's inadequate security, prior thefts, drug use, and tenant complaints about intruders, plus an expert's opinion that the vacant floors were left dangerously unsecured. The district court granted the Bank a directed verdict, finding the rape was not shown to be foreseeable.
Whether a commercial landlord must exercise reasonable care to protect tenants from foreseeable criminal conduct occurring in common areas within the landlord's control.