Boston Radisson Garage — $6.6M jury verdict (2009)
A woman was sexually assaulted in the Radisson hotel parking garage in downtown Boston. The aggravating fact at trial: another woman had been raped in the exact same garage just 12 days earlier. Management did not increase patrol, did not post warnings, and did not alert guests.
A prior similar incident on the property is the most expensive evidence a plaintiff can introduce. Once one assault has occurred, the standard of care for foreseeability resets — and a failure to add documented patrol, signage, or alerts becomes the entire negligence case.
Boston, MA — civil jury verdict, 2009. Reported damages: $6.6M.
Stamford Marriott — gunpoint assault in front of children (2006)
A woman was raped at gunpoint in the hotel's parking garage while her young children were present. Testimony showed the assailant had been roaming the property for days. Hotel staff had not been monitoring the garage and had not responded to reports of suspicious loitering.
Suspicious loitering is the warning sign juries focus on. A documented patrol log that shows the property was walked, that suspicious persons were contacted, and that escalation was attempted is the single most defensible record in a premises-liability case.
Stamford, CT — Marriott premises-liability case, 2006.
Ann M. v. Pacific Plaza Shopping Center (1993) — California's foreseeability test
A shopping-center tenant employee was raped in the early morning at a San Diego strip mall. The California Supreme Court held that the landlord's duty to provide security guards depends on the foreseeability of the criminal act — and that foreseeability typically requires prior similar incidents on the premises.
Ann M. is the case every California premises-liability lawyer cites. The practical takeaway for Sacramento owners: once a prior similar incident is on the record (or on Sacramento PD's CAD), the cost of NOT having documented patrol skyrockets. Document the patrol you have so 'we did nothing' is never the headline.
Ann M. v. Pacific Plaza Shopping Center (1993) 6 Cal.4th 666.
Delgado v. Trax Bar & Grill (2005) — duty triggered by imminent harm
A patron was attacked in a bar parking lot in Pomona, CA. The California Supreme Court held that a business owner has a duty to take reasonable steps — including calling 911 or providing security — when it has actual knowledge of an imminent or 'ongoing' criminal threat, even without prior similar incidents.
Delgado expanded duty beyond Ann M.: if your staff sees a fight brewing or a suspicious person stalking the lot and does nothing, the prior-similar-incident shield disappears. Trained, documented patrol that responds to early warning signs is exactly the standard Delgado contemplates.
Delgado v. Trax Bar & Grill (2005) 36 Cal.4th 224.
Saelzler v. Advanced Group 400 (2001) — why documentation wins or loses
A FedEx driver was attacked by gang members in the parking area of a 300-unit Los Angeles apartment complex with a documented history of violence. The California Supreme Court ruled for the landlord — not because the property was safe, but because the plaintiff could not prove that additional guards or locked gates would have prevented this specific attack.
Saelzler is the case landlords cite to defend. The flip side for owners: causation can swing either way, and the property's documented security posture is exhibit one. A property with a real, time-stamped patrol log is far better positioned than one relying on 'we had cameras somewhere.'
Saelzler v. Advanced Group 400 (2001) 25 Cal.4th 763.
Sharon P. v. Arman, Ltd. (1999) — underground garage assault, no prior incidents
A tenant was sexually assaulted in an unattended underground parking garage in West Los Angeles. The California Supreme Court ruled for the property owner because there were no prior similar incidents in that specific garage — but Justice Werdegar's concurrence flagged that underground garages are inherently high-risk environments owners should not treat as 'no duty zones.'
Underground and multi-level garages are foreseeably higher-risk by environment alone — limited sightlines, isolated stairwells, slow egress. Sophisticated property managers don't wait for Ann M.'s prior-similar-incident standard to be met. Patrol coverage of underground levels is the cheapest insurance available.
Sharon P. v. Arman, Ltd. (1999) 21 Cal.4th 1181.
Sacramento RT light-rail & downtown parking — documented pattern
Sacramento Regional Transit park-and-ride lots and downtown public garages have been the subject of repeated Sacramento Bee, KCRA, and CBS Sacramento reporting on auto burglary waves, catalytic-converter theft rings, and assault incidents — particularly along the Blue Line corridor and at downtown event-night garages. Sacramento PD CAD records for these locations are publicly discoverable.
If your Sacramento property is near a transit hub, event venue, or known-pattern corridor (J Street, K Street Mall, Stockton Blvd, Power Inn, Arden), the foreseeability bar is already low. Owners who add documented patrol now own the 'reasonable measures' narrative if an incident ever lands in court.
Sources: Sacramento Bee, KCRA 3, CBS Sacramento public-safety reporting; Sacramento PD CAD records (discoverable on request).
Cases summarized from public reporting and used here for educational, premises-liability illustration only. Stormhammer Security is not affiliated with the parties involved.