| Court: | DC Circuit Court |
| Facts: | Security guards are being let go from the apartment, and doors aren't covered. Assault and robbery inside the building, rather predictably. |
| Posture: | Appeal from trial, with some sort of finding for the landlord. |
| Issue: | Whether a duty should be placed on a landlord to take steps to protect tenants from forseeable criminal acts committed by third parties. |
| Holding: | Yes. |
| Rule: | There is a duty of care. |
| Reasoning: | Landlord is the only one in a position to take action. Police can't be patrolling inside of buildings. Everyone has the duty to minimize opportunities for crime. Via Javins, there's an implied obligation to provide reasonable conditions. |
| Dicta: | Yes, in some cases, this implies major expenses, and this will raise rents; but as it stands, tenants are already bearing these costs, in the form of the crimes to which they are victims. |