Kline v. 1500 Massachusetts Avenue Apartment Corp.

Sarah Kline (plaintiff) moved into an apartment building owned by 1500 Massachusetts Avenue Apartment Corp. (defendant) in 1959, when all three entrances and the garage were guarded; by 1966, funding and staffing cuts left the entrances largely unguarded even as violent crimes against tenants increased and the landlord became aware of the pattern. In November 1966, Kline was assaulted and robbed in the common area outside her apartment, just two months after a similar assault on another tenant in the same area; she sued, alleging the landlord had a duty to protect tenants from foreseeable criminal acts, and the district court found no such duty existed, prompting her appeal.