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Inspecting 2 Landmark Negligent Security Cases in Maryland


In certain situations, Maryland law enables an injured visitor to sue property owners under the doctrine of premises liability. Within that doctrine, negligent security addresses when a property owner has a duty to prevent the criminal actions of third-party actors.

Under Maryland law, negligent security is only appropriate if there is a special relationship between the property owner and visitor. This type of special relationship usually exists if:

  • The owner was in control of a dangerous condition;
  • The owner knew — or should have known — about the dangerous condition; and
  • It was foreseeable that a customer would suffer harm or injury as a result of the dangerous condition.

With that framework in mind, it is now time to review two important legal decisions that help shape the boundaries of negligent security claims in Maryland.

Scott v. Watson

Scott v. Watson, 278 Md. 160 (1976) is a landmark decision from the Court of Appeals of Maryland concerning negligent security cases. In this case, Scott suffered a gunshot wound in the parking garage underneath his apartment building. Scott later died from his injuries.

A review of Baltimore City Police Department records demonstrated a pattern of similarly violent incidents in the months preceding Scott’s death. These violent incidents occurred on or around the premises of Scott’s apartment building.

Considering these circumstances, Scott’s surviving family members brought a wrongful death action against the owner of the apartment building. The surviving family members claimed that the apartment building owed Scott a duty of care to protect against third-party criminal activity.

In reviewing this case, the Court of Appeals reasoned that property owners must take reasonable measures to protect against foreseeable criminal activities.

Corinaldi v. Columbia Courtyard

In Corinaldi v. Columbia Courtyard, Inc., 162 Md. App. 207 (2005), the Court of Special Appeals of Maryland distinguished several different types of negligent security cases. As outlined in this case, there are traditionally three different kinds of negligent security under Maryland law.

The first kind of Maryland negligent security case involves past criminal conduct. If an owner has actual knowledge of past criminal conduct that occurred on the premises, then there is a duty to take reasonable measures to prevent future conduct of a similar nature.

The second kind of Maryland negligent security case involves a specific assailant. If an owner knows that a specific person poses a danger to their customers or visitors, then there is a duty to take reasonable measures to prevent any such danger.

The third kind of Maryland negligent security case involves immediately preceding events. If an owner has knowledge of relevant events that would make criminal activity foreseeable, then there is a duty to take reasonable measures to prevent such activity.

Do You Need Legal Help?

If you have legal questions about negligent security or other aspects of premises liability in Maryland, it can be incredibly fruitful to reach out to an established Baltimore personal injury attorney. The attorneys at Iamele & Iamele, LLP have proven experience in the field of personal injury law, including negligent security and premises liability. If you need legal help, contact us today for a free initial consultation.


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