Trammell Crow Central Texas, Ltd. v. Gutierrez
Supreme Court of Texas
267 S.W.3d 9 (2008)
Relevant factsFree
A gunman shot Luis Gutierrez four times from behind at long range with no demand for property as he left a mall theater; his family (plaintiffs) sued property manager Trammell Crow (defendant) for inadequate security, presenting evidence of prior mall crimes including 10 violent robberies (none involving fired weapons or serious injury) but no prior murders, while the defense's expert showed the mall's violent crime rate was actually 36 times lower than the surrounding city. A jury awarded over $5 million, affirmed on appeal.
IssueFree
Whether a person with control over property owes a duty to protect invitees from unreasonable risks of crime only if the risk is foreseeable.