Premises security cases.

Practice point: The necessary causal link between a landlord's culpable failure to provide adequate security and a tenant's injuries resulting from a criminal attack in the building can be established only if the assailant gained access to the premises through a negligently maintained entrance.

Student note: While the plaintiff claimed that the defendants should have provided her with a deadbolt lock in addition to the kitchen door lock she purchased herself, she failed to submit any evidence that the original lock provided by the landlord, which she replaced, had not functioned properly or that the original lock did not constitute a minimal security measure adequate to protect her from foreseeable harm.

Case: Ferguson v. Antaeus Realty Corp., NY Slip Op 02628 (2d Dept. 2012).

Here is the decision.

Tomorrow’s issue: Dismissal based on documentary evidence.