Simmons v. Chicago Housing Authority

1994

Court: IL Court of Appeals

Facts: Carol Simmons got raped while visiting her relatives at a housing authority complex. She alleges CHA was negligent in hiring and managing its security guards.

Posture: Awarded $200K at trial. Appeal. (this is maybe an appeal from that appeal?)

Issue: Are the damages proper?

Holding: Nope. Reversed.

Rule: Privity. Plus the guards were there to protect the property, not the people.

Reasoning: No showing that the guards were there to protect people, and no law showing that the CHA had the duty to protect this person.

Dicta: