Doe v. Manheimer

Doe (plaintiff) was raped by an unidentified assailant in overgrown vegetation on property owned by Manheimer (defendant) in a high-crime area, where a prior indoor rape and an indoor robbery of Manheimer's mother had also occurred. Doe sued Manheimer, arguing the overgrowth let the assailant conceal the crime and that Manheimer should have known of that danger. The jury found for Doe, but the trial court set the verdict aside, ruling she had not proven proximate cause as a matter of law.