Rosenbaum

The issue in this case is whether a landlord can be held liable for a tenant’s injuries caused by the criminal activities of third persons off the premises. For the reasons discussed below, we conclude that under the circumstances of this case the landlord had no duty to protect plaintiff from an attack on a public street and therefore affirm the judgment for defendant.

Facts and Proceedings Below

Plaintiff, Debra Rosenbaum, brought this negligence action against her landlord, Security Pacific Corporation, after she was robbed and severely injured on the street in front of her apartment building. We state the facts in the light most favorable to the verdict for plaintiff. (9 Witkin, Cal. Procedure (3d ed. 1985) Appeal, § 278, p. 289.)

In 1985, plaintiff moved into the Plymouth Apartments located at the intersection of 8th Street and Plymouth Boulevard in Los Angeles. The premises consist of two apartment buildings, two garage buildings in the rear and a central courtyard between the buildings. A hallway provides access from the courtyard to the rear driveway and garages. Plaintiff lived in the front comer apartment facing Plymouth Boulevard. Her garage door faced 8th…