Sociology and Negligent Security:

Premise Liability and Crime Prediction

 

Lydia Voigt and William E. Thornton. Jr.

 

Criminological research methods and theories are growing in demand by policy and decision makers, as well as by courts of law. Indeed, the call for criminologists as expert witnesses is not confined to criminal court. Increasingly, criminologists are invited as expert witnesses by the civil court, particularly in premise security liability or third‑party liability suits.

 

Through the vehicle of civil law, premise security liability is the civil liability of property owners to provide reasonable and adequate security to customers and other invited patrons onto their premises. When a property owner fails to provide a reasonably safe environment to patrons and, as a result, an invited individual suffers a criminal victimization such as a rape, armed robbery, or assault by a third party, the property owner may be liable under civil jurisdiction for losses the patron incurs. Relatives of patrons who are murdered on premises are, likewise, subject to civil remedy associated with the loss of a loved one. Losses may include costs associated with physical injury, psychological trauma leading to inability to enjoy life or earn a living, and future income foregone as a result of victimization.

 

To a large extent, the standards necessary to trigger the charge of negligent security on the part of public and private establishments are subject to legal debate and vary from jurisdiction to jurisdiction. The controversy usually focuses on several key questions that generally must be answered when inadequate security is alleged against a property owner or manager in a civil action. Does the owner or occupier of the property owe a legal duty of care to the plaintiff? Was the interpersonal crime foreseeable on the premises? Did the owner or occupier of the property fail to conform to a "reasonable standard of care"? Was the negligence the proximate cause of the assaultive crime upon the plaintiff? Was the plaintiff damaged or otherwise injured as a result of that breach of duty? (McGoey 1990:19).

 

Experts often are called upon to help clarify the issues and to provide defensible guidelines for making decisions or judgments pertaining to questions of "foreseeable crime," 'seasonable standard of care," and "adequate security." Attorneys employ a wide variety of experts to both collect data for their cases and render advice and opinions regarding the grounds for the case. Given that no uniform standard of criminal foreseeability to guide courts exists, the "definition of the situation" proffered by criminologist ezparla at each stage in a premise liability case ‑ beginning from initial conception and moving to deposition to settlement or trial ‑ has a tremendous influence on whether a case is lost, settled, or won. Perhaps in no other area of law is it possible for criminologists to define and set the parameters of legal decisions as well as to establish precedence as in the realm of premise liability.

 

This chapter illustrates, through case examples, how our training in criminology and sociology has been instrumental in influencing the overall development of cases as well as outcomes of specific cases. Much of what we bring to our clients, chiefly attorneys, in terms of methodological and analytical skills comes from our training as academic sociologists and criminologists.1 As premise liability consultants and expert witnesses, we have participated in more than 100 cases, both plaintiff and defense, and have been declared criminological experts by numerous courts in several states. Our consulting practice has brought us in competition with many experts coming from varied backgrounds. Rarely have these other experts brought to clients the panorama of analytical, methodological, and theoretical skills necessary to fully conceptualize, investigate, and develop a case. Indeed, we argue that the very "stuff' of criminology as a discipline strongly lends itself to this particular area of litigation.

 

This chapter introduces our "crime foreseeability model," which we developed utilizing many years of experience in premise liability litigation. The model demonstrates the practical applicability of research methods, theories, and the use of sociological and criminological imagination. Our discussion begins with a review of the history of third‑party criminal liability suits and current developments in civil procedure as they relate to premise security litigation.

 

HISTORY OF PREMISE SECURITY LIABILITY

 

Until recently, most victims of interpersonal violent crimes did not realize that there was another legal avenue available to them for both increased crime protection and financial remedy for their losses. The first major award for an inadequate security claim involved a $2.7 million dollar judgment for entertainer Connie Francis, who was raped in a Howard Johnson Motor Lodge in upstate New York in 1974. Her assailant gained entry through a faulty sliding glass door. Francis alleged inadequate security and presented evidence of past similar offenses being committed against motel guests during the few years prior to her victimization (Gannilli u. )Toward Johnson's Motor Lodge, Inc. 1976).

 

Over the years, there has been a growing trend to expand liability from third‑party criminal actions to include such diverse businesses or entities as hotels and motels, shopping centers, parking lots, apartment complexes, hospitals, fast‑food establishments, bars, casinos, convenience stores, restaurants, airports, train and bus depots, and educational institutions. More recently, municipalities that operate such facilities as public parks, amusement parks, and museums have been held to higher standards of security than in the past and, hence, are subject to civil liability for inadequate security. Even public schools are not immune to civil liability suits from parents who have children hurt by the criminal actions of third parties who intrude on school premises. There is no doubt that the threat of inadequate security suits has motivated owners, managers, and administrators of public and private establishments to be more cognizant of potential criminal dangers to patrons and to respond by making their facilities safer (Wright 1994; Holl and Newton 1992).

 

In the past decade, premise liability tort filings have increased more than 260 percent, with the average settlement being in excess of $545,000 and the average jury award being $3.35 million (Bates and Dunnell 1993). A study of 267 premise security cases reported in The Law Reporter, published by the Association of Trial Lawyers of America, found that the crimes that cause the vast majority of premise liability suits are found in four main categories: rape and sexual assault (44.5 percent), assault and battery (24.9 percent), wrongful death (18.5 percent), and robbery (8.7 percent). The types of businesses most often involved in inadequate security torts are residential properties (37.6 percent), hotels and motels (24.2 percent), and retail establishments (8.4 percent). Others include restaurants, bars, and casinos (6.7 per‑ office buildings (5.1 percent); colleges (3.9 percent); and common carriers (e.g., buses, trains, airplanes) (11.3 percent). Apartment units, parking lots, and garages account for more than 40 percent of the specific locations where crimes are committed against invited patrons (Bates and Dunnell 1993).

 

One reason that rapes result in the highest percentage of premise liability claims is the nature of the violence perpetrated against the victim. In addition to the physical harm that usually ensues with a rape, deep emotional trauma often is associated with the attack. More recently, the fear of contracting AIDS further exacerbates the fear of the victim long after the initial rape. Wrongful deaths in which the victim dies as a result of the negligence of a third party usually result in the highest awards, based upon considerations of lost future earnings and loss of consortium claims by spouses (Bates and Dunnell 1993).

 

COMPETING APPROACHES TO CRIME FORESEEABILITY

 

Three competing schools of thought regarding the criteria necessary to establish crime foreseeability can be found in tort law decisions, chiefly at the state level, regarding premise liability. The first is the impending assault doctrine. Some courts have maintained that a business owner has a duty to exercise reasonable care to protect patrons only from the criminal acts of third parties that he or she knows are about to occur (i.e., the impending assault). If a business owner had knowledge of a crime to be perpetrated against a customer, he or she would be under a legal obligation to either warn or attempt to prevent the impending assault. As a minimum caution, the owner is under obligation to at least warn patrons of potential dangers. Courts have generally maintained, however, that rarely are business owners in the position to actually know that a customer or patron was the target of an impending attack. For example, criminal victimization of acquaintances or relatives that spill over into the commercial areas generally are considered unforeseen unless the manager or proprietor has been put on prior notice.

 

CASE ILLUSTRATION: IMPENDING ASSAULT

A case that occurred a few years ago involved a woman who was assaulted in a strip shopping center parking lot by a man. Upon investigation, we found that the perpetrator was an ex­employee of the company where the woman worked. He recently had been fired by the victim, who was a personnel manager of the company. The man had been stalking her for several days prior to the attack. The court held that the attack upon the woman in the parking lot could not have been foreseen by the shopping center management. The center's management had no prior knowledge of the conflict between the two individuals and, therefore, could not have warned the woman of the impending attack.

 

Other courts accept the notion that a crime is unforeseeable unless the owner or manager knows that there have been a "high" number of similar offenses that occurred on the premises (the prior similar crimes rule). Thus, if a plaintiff is a victim of rape in a business' restroom, and it can be proven that other women have been raped in the restroom in the past, the crime in question could be argued as foreseeable on the part of the business owner. Conversely, pending no prior similar crimes at a site in question, it may be argued by some that the crime was unforeseeable. Recent decisions have called into question exclusive use of the prior similar crimes rule on the grounds that the victims of crime are victimized twice if they are attacked in a facility for the first time. Initially they suffer from the criminal attack, and then they are unable to recover in lawsuits because they were the first victim. The prior similar crimes rule has been likened to the legal maxim, "Every dog is entitled to one free bite." Issues raised against the exclusive use of the prior similar crimes rule have resulted in widening the variables under consideration. In essence, knowledge of a canine's dangerous propensities can be established before the first bite.

 

More recently, courts have examined a greater variety of circumstances in crime foreseeability (the totality of circumstances rule), arguing that, in addition to prior similar crimes, the general circumstances surrounding a criminal incident must also come into play (e.g., other patterns of criminality at a site and crime in adjoining areas, frequency of pedestrian and vehicular traffic, demographic conditions, and security measures such as ingress and egress devices, monitoring technology, architectural design, and guardS.3 The totality of circumstances rule seems to offer a better reasoned basis for determining crime foreseeability because it suggests a multivariate analysis of crime ‑ something sociologists and criminologists have been doing for a long time. Much of the discipline of criminology, including crime measurement, crime etiology, crime prevention, and crime control, supports the components of the totality of circumstances rule.

 

THE CRIME FORESEEABILITY MODEL

 

Although not every case demands an in‑depth investigation of all variables, most cases will require several stages of development. The crime foreseeability model that we propose is based on a checklist of data and information necessary for a systematic and comprehensive case development. It includes standard methods of criminology for collecting data and a rich body of theories to render an opinion on crime foreseeability and security adequacy for a client (plaintiff or defendant). The model introduced here ensures the orderly (i.e., scientifically sound) collection of data and theoretically adequate analysis of data. Our comprehensive and systematic approach to the discovery of information and to the defensibility of evidence is composed of the following areas of investigation:

 

Analysis of prior similar and other interpersonal crimes

Analysis of incident reports and supplemental crime data

Analysis of other types of crimes at the site

Analysis of the level of security at the site

            Physical security factors

            Security plan and philosophy

Review of any relevant security standards

Analysis of social, economic, and demographic characteristics

Nature and profile of the offender

Nature and profile of the victim

 

 

ANALYSIS OF PRIOR SIMILAR AND

OTHER INTERPERSONAL CRIMES

 

Irrespective of the legal debate (e.g., Siebert v. Vic Regnier Builders, Inc. [1993]) regarding the problems associated with the exclusive use of prior similar crimes rule, our model necessitates the acquisition of this information. It is important to conduct a complete crime analysis of same­type crimes utilizing police statistics (e.g., offenses reported to local police) for the specific geographical locale (e.g., police district, zone, or subzone) where a case is located.4 This information is not used exclusively but represents only the first step in a more comprehensive approach.

 

For example, if a case that is being investigated involves the rape of a woman in the parking lot of a shopping center, we begin with an examination of the occurrence of other rapes at the site and in the surrounding area. An arbitrarily designated geographical area with specific boundaries can be used for this purpose. However, police district and zone maps are considered standard for the display of this information, especially because official crime data are collected in relation to such districts. Specific crime rates then can be generated for the area in question as well as for an entire city.

In addition, crime analysis almost always should include a rate analysis of the major Uniform Crime Reporting (UCR) index offenses (i.e., murder, rape, robbery, aggravated assault, burglary, larceny theft, motor vehicle theft, and arson). It is impossible to speak of "low" or "high" crime areas without some means of comparison (Thornton, McKinnon‑Fowler, and Kent 1991).

 

Through a general crime statistical analysis, it may be possible to show that the rate of violent crime at a site is substantially higher (or lower) than that for surrounding areas or, possibly, for an entire city. Thus, whether or not prior rapes had occurred on the premise, the relative dangerousness of the site and the relative adequacy of security can be established. Based on our experience as premise liability consultants, we have found that armed robbery is one of the best indicators of an area's or city's general level of "dangerousness." Armed robbery, unlike other crimes of violence, usually involves strangers rather than acquaintances or relatives.

 

Utilizing official statistics, we rank armed robberies by police districts and zones and subzones for several years, statistically weigh these, and create an index that can be used for comparative purposes. This index can be further decomposed by controlling for population size, types and numbers of commercial establishments versus residential facilities, and so on. For instance, the robbery rates per 100,000 population at a shopping center and in the surrounding area (e.g., number of customers per day or number of cars in the mall parking area divided by the number of incidents of robbery) could be computed. If, for example, the robbery rate is lower at a shopping center where a rape

occurred than in the surrounding area, it would be difficult to argue

inadequate security. Computing per capita crime rates for both the

specific crime in question as well as other index crimes,especially

armed robbery, for "defendant" premises and for the surrounding com­-

munity cannot be overvalued. This places a particular victimization in

a broader crime and security context.

 

CASE ILLUSTRATION:  FAST‑FOOD RESTAURANT

 

An example of a defendant case in which we served as consultants illustrates the need for a thorough analysis of prior similar crimes in conjunction with a more general crime analysis. We were retained by an attorney representing a Mexican fast‑food restaurant that recently had gone out of business. The plaintiffs in the case were the parents of a young man who had been murdered in a parking lot adjacent to the restaurant. The young man and his girlfriend parked in the lot (about 50 feet away), walked to the restaurant to eat, and, upon returning to their car, were victimized. Although the owners of the business did not own the adjacent parking lot, over the years, customers often parked in the lot because of its convenience to the restaurant. Management had made no effort to discourage parking in the lot, which was locate next to an abandoned mechanic's shop. Upon investigation, our analysis of prior similar crimes at the restaurant revealed two other murders in the parking lot adjacent to the business. We also uncovered several armed and simple robberies of patrons and cashiers working in the restaurant. The management of the business had no security measures in place, in spite of the relatively large number of past interpersonal criminal offenses. Many of the crimes had occurred at night, and the lighting in the parking lot was inadequate. The general area surrounding the business likewise was ranked high in both the volume and the rate of violent offenses in comparison with other police districts in the city.

 

Our opinion to the attorney was that, given past crime events on the site, the general dangerousness of the surrounding area, and the absence of even minimal security measures, the deceased victim's parents had a very strong case against the Mexican restaurant. The owners of the business had not, in our opinion, responded in a responsible manner to protect customers, given the past crime trends on and off the site. There was a high probability that a crime such as the one that occurred could have been foreseen. Our advice to the attorney was to settle the case early. The case was, indeed, settled for the defendant. We later found out that the owners had decided to close this particular restaurant because they were having difficulty hiring employees, who were frightened by the past reputation of the business as being a dangerous place to work.

 

 

ANALYSIS OF INCIDENT REPORTS AND

SUPPLEMENTAL CRIME DATA

 

As part of the crime analysis for specific crimes on and off a site, more detailed information can be obtained by acquiring the official incident reports available from law enforcement agencies. If the case is closed and does not involve juvenile offenders or victims, such reports are public record and can be obtained easily for a fee; some police departments allow researchers to view such reports on microfiche at no charge. If the case is still active, a subpoena duces tecum must be obtained in order to access this data. Included in these reports are detailed information regarding the victim and the offender and the circumstances surrounding the crime event. In addition to these reports, more information may be gleaned about the crime and the crime scene from depositions and other materials that invariably accompany a civil action for third‑party criminal liability and may be requested from the attorneys representing the case.

 

Often, the experts must conduct interviews and develop other supplemental information using standard social science methodologies. For instance, if an official incident report appears incomplete or somehow confusing, the expert may attempt to check out certain details or facts by going on location and interviewing individuals in residences or businesses where the incident took place. The expert also may conduct interviews to confirm or refute certain perceptions of dangerousness ("fear of crime") or opinions regarding the adequacy of security on the premise. If this information is intended to be used as evidence in court, all the rigors of the scientific method come into play. Increasingly, courts place emphasis on "scientifically derived information," that is, challenging expert testimony on scientific grounds.

 

CASE ILLUSTRATION:

A CITY PARK'S SAFETY AND SECURITY

 

In a past case, we served on the plaintiff's side against a city park commission for not providing reasonable security for a man who was shot and robbed in a park restroom. Part of our task was to establish that enough past crimes had occurred in the park (40 acres) (and periphery of the park) to merit increased security for the protection of park patrons. Park security (which, in this case, amounted to two untrained groundskeepers) claimed that they maintained very few records of crimes that occurred in the park. The security director, an accountant, suspiciously testified that films regarding past criminal activity in the park could not be found, although he was sure there was little criminal activity in the park. We, therefore, requested from the crime analysis section of the police department a printout of all offenses that occurred in the park and the police zone and subzone in which the park was located for a period of five years prior to the incident.

 

Based on interviews with residents living on the periphery of the park and on interviews with a systematic sample of park patrons, common knowledge

indicated that many crimes occurred in the park. We consequently expected that our official police statistics would confirm the relatively high crime rate for the park (and adjoining areas). We were surprised to find only a few officially documented crimes from the reports (a computer printout with a police item number, address, date, time, and type of crime occurring). For instance, the crime statistics for the area uncovered eight serious interpersonal crimes in the park during the same year of the crime in question. Something was wrong. Subsequent investigation (including a door‑to‑door survey of the residents in the adjacent area and an analysis of the more detailed police incident reports) revealed that, when a park crime was reported, the victim or bystander usually proceeded to the nearest phone (e.g., pay phone booths across the street from the park) or to a home on the boundary of the park. Consequently, the address where the call was placed rather than the location of the criminal act (i.e., the park) ‑ was registered on the official police report. As a result, the crime appears to have taken place outside the park. In fact, this was the case with the crime in question. This practice, we found, was quite common and reflected a definite flaw is the police reporting system.

 

Only by requesting a more detailed incident (and supplemental) report (i.e., the officer's field interrogation report and subsequent follow‑up) could we pinpoint specific crimes that occurred within the boundaries of the park. Consideration of incident reports, however, still failed to account for the discrepancies between official reports and the common perceptions of this area as having a high crime rate.

 

In an effort to augment the official statistics, we did a content analysis (for the same years) of the local newspaper and discovered a few additional crimes reported to have occurred in the park that did not show up in the official statistics. We concentrated on those crimes that we could definitely document (i.e., those that occurred within the boundaries of the park), and then we examined more closely those "official" crimes that occurred on the boundaries of the park and adjacent neighborhoods. A comparison of crime patterns occurring in this particular police district (or, more precisely, the geographical subzone of the district) with those occurring in other districts of the city did suggest that this section of the city experienced a relatively higher number of victimizations. Especially in relation to its size, population, and square miles, the park was the site of a disproportionately high number of crimes. We also uncovered a survey conducted by the city a few years earlier that drew a similar conclusion. The survey included a fear of crime inventory in which the citizens in the area indicated that they were seriously concerned about crime and their protection.

 

Our opinion to our client, and the subsequent opinion in court, was that, given the overall crime patterns and lack of security in the park, it was logical to infer that this type of crime was reasonably foreseeable. Furthermore, we also offered an analysis of the location and architectural design of the restrooms in the park that was based on an area of criminology known as "crime control through environmental design" (Harries 1974; Jeffrey 1977; Kaplan, O'Kane, Lavrakas, and Peace 1978; Rubenstein, Murray, Motoyama, and Rouse 1980; Crowe 1991). The judgment for the case ruled in favor of our client, and he was awarded in excess of $2 million. The judgment, however,

later was overturned at the appeals level, reverting back to the exclusive prior similar crimes rule.

 

ANALYSIS OF OTHER TYPES OF CRIMES AT A SITE

 

In addition to the examination of prior similar and other interpersonal crimes at a site (and in the surrounding area), a crime analysis also must examine other types of crimes, such as property offenses, that may have occurred on a premise. Although property crimes such as auto burglaries or auto thefts usually are not good predictors of crimes against the person at a site, the prevalence of large numbers of auto burglaries, even in the absence of prior similar violent crimes, may be used to suggest that opportunities for more serious crimes against customers or other invited guests may occur. Certain types of property crimes, such as shoplifting in a store, may have no relationship to either other property crimes or interpersonal crimes occurring in a parking lot against patrons. In general, even a large number of minor property crimes are not substantially similar enough to predict future stranger violence in many situations. At least some empirical research has suggested that property crime statistics are not valid indicators of future crimes of violence. For instance, an analysis of UCR data indicated that one aggravated assault can be expected in 1,000 motor vehicle thefts and that one murder can ensue from 45,000 motor vehicle thefts (Security Law Newsletter 1990). Courts usually do not accept the expert opinion that minor property crimes at a site are good predictors of violent crimes.

 

It is worth noting that comparing crime trends, even property crimes, from one site, such as a shopping mall parking lot, with those at another comparable site in the same vicinity can be used to point to possible security problems. If one shopping center parking lot, for example, has roving security guards and, as a result, has a minimal amount of auto burglaries or auto thefts, and another shopping center in the same vicinity has no guards but a large number of property crimes, an argument can be made for the relative inadequacies of security at the latter site. Thus, although the numbers of minor property crimes may not be valid indicators of future crimes of violence, they can indicate the relative adequacy of security and, thus, be useful from that perspective.

 

THE LEVEL OF SECURITY AT A 8M

 

Levels of security at a site can range from minor precautions (e.g., written warnings, signs, fencing) to major precautions (e.g., contract or proprietary security personnel, elaborate security lighting, full perimeter security fencing, electronic monitoring systems, intrusion detection devices). The nature of the third‑party criminal event and the past crime trends, if any, on the premises and in the surrounding area generally dictate the level of security necessary at a particular site.

 

Standard investigation of a case usually requires a security evaluation or assessment, in which a number of key factors must be examined. Such an assessment includes an intensive physical examination of the premises in order to determine the current state of security, to locate or assess weaknesses, and to make recommendations for "hardening" the facility in order to prevent future criminal intrusions. Obviously, in a defense case, the investigator tries to emphasize existing security measures and points to their general adequacy. In a plaintiff case, weaknesses in security at a facility become the focal point, and recommendations of security improvement measures that may have prevented a third‑party criminal offense are stressed.

 

Although each site or facility is unique in terms of the actual risks it is designed to control and its subsequent vulnerabilities, two general areas of crime prevention methodology may be addressed in premise liability cases as being necessary for a reasonable standard of care to protect customers and other invited guests; environmental design and physical security factors and security plan or security philosophy.

 

ENVIRONMENTAL DESIGN AND

PHYSICAL SECURITY FACTORS

 

A number of physical environmental variables have long been associated with crime deterrence or crime displacement. Under Crime Prevention Through Environmental Design the architectural design, placement of buildings, parking lots, and movement generators (e.g., walkways, overpasses, corridors, and halls) at a site can affect the opportunities for criminal events to occur. Crime Prevention Through Environmental Design chiefly attempts to achieve crime prevention by modifying the physical features of the target setting. For example, it offers methods for designing or redesigning commercial and residential buildings, other commercial areas, parks, or even entire neighborhoods in order to reduce crime. These methods may be as sophisticated as Oscar Newman's (1973) design directive for public housing developments or as simple as locating an automatic teller machine so that it lends itself to natural observation.

 

Another body of theoretical works that provides a rich supply of theory and research evidence that experts may use to "support" conclusions regarding environmental and social conditions associated with high and low crime trends is routine activities theory (Cohen and Felson 1979; Felson 1987). The routine activity approach to crime rate analysis suggests that, by guiding the natural flow of individuals and activities so that offenders and targets rarely meet in the absence of natural, informal controls (e.g., public observation), crime temptation and victimization may be reduced.

 

SECURITY PLAN AND SECURITY PHILOSOPHY

 

Many premise liability cases hinge on the presence or absence of a master security plan at the establishment. Such a plan should address such things as the establishment's or management's philosophy toward security, allocation of resources for security, the name or type of security employment (is there a security director with a clear line of authority and accountability?), the name of the security plan, training of security personnel (is the training of security guards adhering to state licensing requirements or industry?), clear direction for security personnel, maintenance of records of problems and criminal events (e.g., incident reports), integration of security hardware into a secure plan, integration of local law enforcement into the master plan, coordination of security codes, and periodic review of the security program.

 

A security plan, of course, must be carried out on a daily basis if it is to be of any use to a particular establishment. Failure to implement security procedures, even if they exist on paper, can be just as bad from a liability stance in some states as having no security plan at all. Usually, the first step in judging the adequacy of a security plan is to do a security assessment of a site, including an analysis of the types of criminal events that occur at a site and in the surrounding area. We have used the illustration below in several different cases that required comparative data regarding levels of security in relation to crime patterns and citizens' perceptions of fear of crime.

 

CASE ILLUSTRATION:

SECURITY ASSESSMENT OF PUBLIC HOUSING DEVELOPMENTS

 

Surveys sponsored by the Department of Housing and Urban Development as well as several national conferences on public housing show that the quality of life of public housing residents is reduced more by crime and fear of crime than by any other social problem. Crime analysis studies conducted by Brill and associates (1972, 1973, 1974, 1975, 1978) show that crime rates in various public housing complexes are five to ten times higher than the national average. More recent studies, many undertaken by the Department of Housing and Urban Development, place the rate at a much higher level (Robinson 1985). Studies of residents who live in public housing uniformly report that 60 to 70 percent of respondents indicate that it is very dangerous to go out of their apartments at night. Several studies undertaken of New Orleans public housing residents over the years indicate similar findings (e.g., Criminal Victimization Surveys in New Orleans 1977; Neighborhood Profile Series in New Orleans 1980; Thornton and Voigt 1986). Victimization in public halls, elevators, and other common areas particularly are cited as being dangerous. Parents especially fear for the safety of their children and have no assurances that they can play safely on the grounds of the developments, even during daylight hours. Thornton and Voigt (1984‑86) found that the children in public housing developments often have a view of the world much different than that of middle‑class children living in private residential areas. Children who live in public housing, as early as three or four years old, see the world as a dangerous place, one in which survival is highly questionable and dependent on street skills rather than school sldlls.

 

Given this backdrop, we were retained by a large public housing authority to examine specifically those types of crimes committed in ten public housing developments with a combined tenant population of about 100,000; conduct a residential survey of crime and ways to combat crime in the developments; review existing security measures, including an environmental assessment of each complex; and provide the data necessary to develop a comprehensive security plan for the public housing developments (Thornton and McKinnon 1992).

 

Our crime analysis utilized official data spanning a 5‑year period for each housing complex. Major UCR index crime categories were employed, with special attention given to drug‑related homicides and other interpersonal crimes of violence, such as rape and armed robbery, that occurred in the public housing boundaries. A separate analysis of crimes in surrounding neighborhoods of the developments was also completed. A property and violent crime index was calculated for each site for every year that data were collected.

 

Our tenant survey revealed that structural and physical security appeared to be the overwhelming concern of tenants. Everyone felt that limited access to the developments would be a key factor in eliminating the outside influences that terrorized the residents and their children. Some of the suggestions made by residents included cutting off streets to limit access, constructing attractive, contemporary fencing in and around the development, enhancing lighting, and redesigning the configuration of the buildings. Along with modifications to the area surrounding the perimeter of the development, residents suggested a need to modify the buildings themselves. Residents stated many times that a large proportion of the illegal activities occurring in the developments are conducted in the hallways of buildings. There was general agreement that these hallways should be eliminated and replaced by exterior stairs.

 

Our audit of existing security and vulnerabilities was aided greatly by tenant input and included a site‑by‑site checklist and dueled analysis of such things as location of buildings in relation to one another; ingress and egress patterns of buildings, sites, and parking lots; existing lighting; existing police patrols; maintenance records of buildings and grounds; location of public transit stops; pedestrian and traffic flows onto sites; surrounding neighborhood crime magnets; and existing housing authority security in place patrols, past incident reports, personnel, and so on.

 

Our recommendations for a comprehensive security plan for the developments included several categories: physical environmental recommendations, social environmental recommendations, drug control and prevention recommendations, law enforcement and security recommendations; and housing authority management recommendations. .

 

 

Under physical environmental factors, recommendations were made regarding type and placement of outdoor lighting, ways of controlling penetrability of sites, ways of enhancing territoriality of tenants by installing barriers, defining and enhancing private space boundaries for housing units, and clustering multifamily dwellings with well‑defined common areas such as courtyards and playgrounds. We also recommended reducing tenant density by moving or tearing down abandoned buildings, which served as havens for drug users.

 

Under social environmental factors, the recommendations involved the enhancement of tenant cohesiveness and leadership in relation to apartment management; the development of more community service activities, especially for juveniles (e.g., expansion of afterschool and weeknight activities for the children); and domestic crisis and family support centers.5

 

Under drug control and prevention, the recommendations concerned greater law enforcement efforts to target "upper level" drug dealers in and near public housing. Likewise, we recommended that drug prevention programs be established or enhanced for public housing residents.

 

Under law enforcement and security, the recommendations focused on a plan to coordinate the housing authority and the metropolitan police in an effort to establish cooperative approaches to crime prevention and crime control. More specifically, the recommendation addressed the need for dedicated law enforcement to be assigned to specific housing developments rather than utilizing periodic patrols that just drive through the developments occasionally. It also was recommended that existing housing authority security be enlarged with better trained and better deployed personnel according to a comprehensive security plan.

 

Security plans and assessments such as this one are not uncommon. People residing in housing developments not only are more aware of their crime problems but also are more likely today to demand that their rights to live in safe environments be regarded by public authorities. Residents of public housing developments who are victimized by crime are increasingly bringing successful liability suits against municipal authorities. This trend is consistent with the greater likelihood that many businesses and public entities will develop comprehensive crime control and prevention plans and programs as part of their routine operations and management (e.g., universities, schools, hospitals). The growing need for professional crime and security evaluations offers significant opportunities for practicing criminologists.

 

REVIEW OF INDUSTRY STANDARDS OF SECURITY

 

Over the past few years, business‑specific regulations have been proffered by various professional organizations (e.g., National Association of Chain Restaurants, National Association of Convenience Stores, International Council of Shopping Centers, Property Management Association, American Bankers Association, International Association for Healthcare Security and Safety). In addition to regulations regarding the operation of a particular business or franchise, minimum security standards are often set in place as a model to guide business owners.

 

For example, crime prevention studies of ways to reduce convenience store robberies suggest that designing stores to enhance visibility from the street, eliminating concealed access, closing stores between midnight and 6 A.M., and utilizing more than one sales clerk can be successful in reducing robberies (Weapons Against Crime 1994; Hunter and Jeffery 1992). In addition, the National Association of Convenience Stores provides training for store owners and managers in robbery deterrence through various seminars and other publications (National Association of Convenience Stores 1987). Convenience store owners who have a crime perpetrated against a customer or salesperson and who have not familiarized themselves with crime prevention strategies used in their particular industry run the risk of being held to a higher level of accountability than store owners who avail themselves of all

 

possible knowledge and ways to reduce the probability of a crime occurring at their place of business. It is the responsibility of the crime expert to be knowledgeable of the standards in the industry.

 

The development of standards providing minimal guidelines for security is relatively new. Therefore, assessments of the effectiveness of these standards are greatly needed and frequently become the focal point of civil lawsuits. These recent developments offer criminologists working on such impact or outcome assessments groundbreaking opportunities to study the corresponding effects of security policies and plans and to contribute to the development of security stands in the future.

 

Public schools, for example, are not immune from civil liability and litigation as the result of crime and violence. The problem of school crime and violence is serious. At least 40 percent of the robberies and assaults on teenagers occur in schools (Rapp, Carrington, and Nicholson 1992:2‑3). Victims of school violence have responded to school crime by demanding that schools provide an orderly and safe environment or compensate victims for their injuries. School systems largely remain under local control with respect to the operation of schools on a day‑to‑day basis. Some minimum standards for securing the safety of students and faculty have evolved over the years, with many coming from research and guidelines set by the National School Safety Center located at Pepperdine University (School Safety Check Book 1990).

 

Various approaches to security measures have been attempted in order to curb public school crime and violence. Most schools use relatively unobtrusive measures to control the problem; however, stricter, more traditional security measures also are used to control school violence. The less intrusive security measures include limited ingress point into a facility; the use of visible student, faculty, and visitor identification cards; monitoring of ingress and egress points into a facility; the use of signs informing visitors to check in at the main office; supervision of student restrooms, especially in primary and elementary

schools; putting greater distance between the school and public transportation (e.g., moving bus stops farther away from school grounds); the implementation of a security plan at the school involving all personnel and students in creating a safe environment; the involvement of parents in the school security and safety plan; the establishment of a neighborhood school watch program, involving residents in neighborhoods near the school; a well‑organized and carefully monitored department of safety and security for the municipal school district and office; the creation of conflict resolution programs in the school; and the establishment of an incident and tracking system in the school to identify problems and potentially dangerous students (or staff and faculty).

 

In some cases, more intrusive security measures have been implemented (especially in high crime schools located in high crime areas). Such measures include surveillance cameras placed in "hot spots" (e.g., halls, cafeterias, playgrounds, open spaces surrounding the school);

 

metal detectors at ingress points in the school; school security personnel making regular rounds in the school; and periodic searches of student lockers for "reasonable cause" cases, and so on.

 

The development of standards providing minimal guidelines for security is relatively new. Therefore, assessments of the effectiveness of these standards frequently become the focal point of civil lawsuits. These developments offer criminologists working on such impact or outcome assessments groundbreaking opportunities to study the corresponding effects of security policies and plans and to contribute to the development of security standards in the future.

 

Schools were never intended to be minijails, nor were they designed to be urban or suburban "fortresses" walled off from their communities. We have found that the more traditional security measures, when applied to an educational setting, often alter the very atmosphere of the school, creating an environment not conducive to learning. In cases involving security at public schools, we usually help defense attorneys develop arguments and justifications for less intrusive, more informal, and more community oriented security measures.

 

CASE ILLUSTRATION:

SECURITY ASSESSMENT OF A PUBLIC ELEMENTARY SCHOOL

 

As consultants retained by a law firm representing a metropolitan school board, we were asked to assess security at an elementary school where an alleged incident of sexual battery occurred between two learning disabled adolescents; one was a student at the school, the other had been a student at the school. The police did not file formal charges because of the lack of evidence in the case; there was a reasonable suspicion that the alleged sexual act was one of mutual consent. The mother of the 14 year old, however, filed a premise liability suit against the school, alleging that the school created a dangerous environment for her son.

 

The neighborhood school was relatively small, with fewer than 500 students, and had a reputation for its caring and concerned faculty and administrators. It was located in what might be described as a lower income, working‑class community with a moderate degree of criminal activity as evidenced by an examination of property and violent crime trends over a 5year period prior to the incident in question.

 

According to our security assessment, the school met the minimum standards provided by the National School Safety Center. It was a wellmaintained facility with a ten‑foot chain‑link fence enclosing the full perimeter of the site. However, we found that there were several unmonitored ingress points to the school. The restroom where the incident occurred was near an open and unmonitored gate on a side street adjacent to the school.

 

Our review of internal incident reports maintained by the school revealed no prior sexual incidents between students, and aside from a few behavioral problems with some students, no serious offenses had ever been reported at the school. Official police reports for the area revealed the same. Aside from two burglaries that occurred after school hours, no official crimes had been reported.

 

Our opinion in the matter was that, given the lack of prior incidents at the school, given the high level of supervision that was evidenced by teachers and staff, and given the lack of evidence of an actual sexual assault having occurred, the offense in question was not reasonably foreseeable by the school. However, our security assessment of the school indicated that several changes were warranted in order to better control strangers' access to school grounds. Although there were numerous signs around the campus indicating that visitors must check in with the main office, several ingress points into the school made it difficult to prevent nonschool personnel from entering the school. We recommended, in particular, that the open gate near the restroom in question either be locked (which would not violate fire codes) or be monitored. Likewise, we recommended that the number of access points in the school be reduced to only those that could be monitored or watched by school personnel. We also recommended that a formal plan be instituted by the school to ensure regular checks on restrooms during the school day; no such plan had been formally in place. As part of a larger range plan, we recommended developing greater community ties and giving more attention to community‑oriented security approaches. The case never went to trial; it was settled out of court. Our recommendations, however, were accepted and have been implemented.

 

ANALYSIS Oh SOCIAL. ECONOMIC. AND

DEMOGRAPHIC CHARACTERISTICS

 

A thorough analysis of the social, economic, and demographic characteristics of an area are of utmost importance in any crime foreseeability study.6 Through hundreds of crime prevention studies, criminologists have found correlations between certain types of demographic data and street‑type crimes. Census data are very useful for this type of analysis (Voigt, Thornton, Barille, and Seaman 1994).

 

Census maps allow the researcher to analyze even neighborhood block level data. It is possible to obtain detailed information about a particular area, including average household income, percent of rentals versus home ownership, number of abandoned or substandard houses, number and type of multidwelling units (e.g., apartment complexes), government subsidized houses, ethnic dispersions, and the like. Other data sources that supply regional data can be found is most locales (e.g., neighborhood profile studies, chamber of commerce, and marketing studies). Geomapping software (utilizing digital geographical files and various attribute data) to plot crime data on census maps in relation to specific social demographic variables is also available. Such software allows researchers to engage in innovative types of crime analysis. For example, "hot spots" can be targeted in terms of specific types of

 

interpersonal and property crimes by geographical areas as small as city blocks. It also is possible to plot, depending on available data, offending patterns to determine the "routine activities" of offenders (Felson 1987; McIver 1981; Cohen, Felson, and Land 1980). These data are invaluable in trying to determine the "career patterns" of certain types of offenders within specific geographical locales. This new computer technology is revolutionizing the uses of census and crime data,

 

not only by criminologists but also by urban planners, developers, law enforcement personnel, and courts.

 

Although each crime site must be analyzed on its own merits, criminologists for a long time have found that several demographic factors are empirically correlated with crime trends. Generally, the interdispersement of residential properties with commercial properties is associated with greater criminal opportunities, leading to the victimization of people and property. For example, residential complexes located on direct routes to bars, convenience stores, fast‑food restaurants, and, especially, liquor stores usually suffer from higher rates of interpersonal crime (e.g., rapes and armed robberies) and property crime (e.g., burglaries and auto thefts) than complexes located

 

in exclusively residential areas. Again, as mentioned earlier, the presence of public pathways substantially adds to criminal opportunities. Even the location of public transit stops such as bus stops can have an impact on criminal opportunities at a site (see, e.g., Institute of Transportation Engineers 1985). Also, the presence of public schools in inner city residential neighborhoods often is strongly correlated with property crimes. Neighborhoods that have larger proportions of owner‑occupied dwellings usually experience lower crime rates than neighborhoods characterized by rental properties, mixed land use, and public housing (e.g., Section 8 or other types of government subsidized

 

housing). These types of factor‑related trends suggest that the practical application of sociological crime theories and empirical research evidence is great. Expert analysis of sociodemographic factors may be easily supported by an extensive body of theory and research (Stark 1987; Shaw and McKay 1969; Chilton 1964; Bordua 1958; Lander 1954).

 

THE NATURE AND PROFILE OF THE OFFENDER

 

Generally, little is known about offenders. As most experts who study crime know, the clearance rates for certain types of crimes are extremely low. For example, according to latest UCR data, the national clearance rate for the crime of robbery was 24 percent, and the clearance rate for aggravated rape was 50 percent (regional clearance rates for rape are substantially lower). Crimes such as murder have somewhat higher clearance rates, about 65 percent nationally; however, because more than 50 percent of murder victims are either related to or acquainted with their assailants, this higher figure is not surprising (Uniform Crime Report 1993).

 

            Despite the generally low clearance rates, some offenders are actu­

ally arrested and convicted for the crimes that they commit against

invited guests and patrons to public or private establishments.

Interviewing an apprehended offender can, in some instances, be of use

to the crime expert in a civil liability suit. If an offender indicates, for

example, that he/she selected a victim at a particular site because it

appeared that security was weak, this information can be damaging for

the defendant (Brill 1990). Obtaining a profile of the offender (or, at

least, a prior offense history ‑ arrests and convictions) may be of use

in security negligence cases for several reasons.                        j

 

Simply counting prior murders at a site such as an apartment complex without examining what David Luckenbill (1980) refers to as the "murder transaction" (the relationship between the offender and the victim) often can result in a "false" count of murder (p. 276). If several stranger‑opportunity murders have occurred in an apartment complex with no apparent concern on the part of management to provide minimum security measures,, the past number of such offenses becomes extremely important from a crime foreseeability standpoint (Thornton et al. 1991).

 

On the other hand, domestic or acquaintance‑related assaults, rapes, and even homicides may fall outside the parameters of crime foreseeability in third‑party liability suits. For example, a disgruntled boyfriend who stalks his girlfriend to a place of business and then assaults her would probably not be in the same crime foreseeability category as a patron who is assaulted by a stranger in the same place of business. Both crimes violate the same criminal codes, and the offenders can be charged and arrested with the same violent crime. From a civil liability standpoint, however, it is not reasonable under most situations to hold the business owner responsible for the domestic assault (recall the impending assault doctrine). He or she, given no warning, could not reasonably foresee that such an offense might occur at the place of business.

 

Recent research on workplace violence indicates that employers are increasingly legally obligated to protect employees, especially women, who have been repeatedly threatened or harassed on the job by exspouses or ex‑boyfriends (or by other employees). Documented repetitive behavior in the form of threats, stalking, surveillance, and the like can signal to the employer that potential assault or worse is possible at some point in the future (Thornton, Voigt, and Wallace 1994).

 

Certain types of particularly heinous or dangerous offenders who have severe character disorders or mental illnesses (e.g., antisocial personality, conduct disorders, or psychoses) or who otherwise commit bizarre, one‑of‑a‑kind types of offenses (e.g., rampage or mass murders) present threats to public or private establishments that cannot reasonably be predicted or deterred by usual security methods. It would not have been possible, for example, for McDonald's management in San Ysidro, California, to have predicted that James Huberty would murder 21 people at their place of business in 1984. In fact, Lopes v. McDonald's (1987) summary judgment was upheld for the defendants on the basis that mass murder is not foreseeable, there was no duty to prevent unforeseeable events on the part of McDonald's, and any breach of duty in failing to employ arced guards was not a proximate cause of injuries and death to customers.

 

CASE ULUSTRA77ON:

FORESEEABILITY OF CFO= BY MENTALLY ILL OFFENDERS

 

In this case, we were retained by the attorneys for the defendant, who was the manager of a multiple apartment complex for a large elderly population. The granddaughter of an elderly woman, while visiting her, was dragged from the complex parking lot into a back woods bordering the complex The young woman was raped and murdered. The plaintiffs (the woman's family) alleged that security was inadequate for what they believed to be a relatively high crime area. They believed that the crime should have been foreseen by the management and that measures should have been taken to prevent the crime.

 

In our crime analysis, we found that the complex, including the surrounding area, was a relatively low crime area. We also uncovered that the management, irrespective of the relatively low crime levels, did evolve a solid security plan. A security guard was hired to patrol both inside the complex and outside in the parking lot. Trees and shrubs in an adjacent lot had been cut down in order to increase visibility. Lighting was installed in the parking lot. A back fence was not there at the time of the offense but was erected immediately after the crime occurred. Whether the back fence could have prevented the crime in question is, of course, debatable.

 

Upon investigation, we found that the offender in this case had been apprehended. The offender himself was also a guest of one of the tenants of the apartment complex. It was further uncovered that the offender had an extensive history of a mental disorder (antisocial personality disorder) of which violent outbursts were symptomatic. He had been charged with murder (of a young mother), attempted murder (of a 3‑ and a 6‑year‑old), and two prior rapes, for which he was unable to stand trial and was judged mentally incom­petent and committed to a state mental hospital, where he stayed for ten years. He also attempted to kill one of the orderlies in the hospital where he was committed. The man was released by a psychiatrist and judged to be not dangerous just one week prior to the rape‑murder incident.

The victimization of the young woman was certainly tragic. Given the circumstances of the case, however, the crime could not have been foreseen or reasonably prevented by the management of the. apartment complex. The case was settled and never went to trial.

 

THE NATURE AND PROFILE OF THE VICTIM

 

Criminologists only recently have developed an interest in the victims of crime. Typologies of victims normally have one or two funda­mental bases or variables, specifically the relative responsibility of the victim for the crime (i.e., to what degree is the victim culpable for the actions of the offender) and the relative vulnerability of the victim to crime (i.e., what social conditions or environments lead to more or less risk of crime for the person). Using these two variables (responsibility and risk), criminologists attempt to explain the dynamic and varied relationship between the criminal and the victim (Voigt et al. 1994:101‑103).

Complete innocence is the most commonly accepted category of victimization. It includes people who did nothing that conceivably could have elicited criminal action. They have no culpability for' the crime. Unintentional facilitation is unwittingly, carelessly, or negligently making it easier for a crime to occur, such as leaving car keys in the ignition of a car or leaving a door to an apartment unlocked. If careless­ness increases the likelihood of crime and there is a reasonable pre­sumption that the crime could have been prevented, does the victim bear some small social, if not legal, responsibility for the crime? Some say yes; considering that nearly 50 percent of burglaries take place without any forcible entry, the victims, if even unintentionally, establish themselves as easy marks.

Victim precipitation, on the other hand, occurs when a person will­fully initiates the encounter with the eventual offender, directly entic­ing, challenging, insulting, provoking, or even initially assaulting the person. Victim precipitation is most common in homicides and aggra­vated assaults. It is estimated, for example, that about 20 percent of homicides involve prior provocation from the victim (Wolfgang 1958; Bordounis 1974).

 

CASE ILLUSTRATION:

DhOe att DOES THE USE OF NEE CONSTITUTE VICTIM PRECIPITATION?

 

The attorneys for the plaintiff retained us as consultants for this case. The case involved a multiple list of defendants, including a hotel, a city park, a private security company, and a travel magazine, to name just a few.

 

A woman accompanied her husband on a business conference trip. While the husband attended the conference, the woman used the time for sightseeing. She noted a travel magazine advertisement for a well‑known park in the tea' her checking with the hotel concierge regarding the relative safety and general directions to the park, she hailed a taxi cab and by 10:30 Am. was dropped off at the park, where she planned to take pictures. She had received no warning from anyone in the hotel ‑ nothing regarding the relative safety of the park was cited in any of the magazines or brochures advertising the park.

 

This particular city park was regarded as s very high crime rate area. The Park borders on a public horsing development that also experiences among the highest crime rates in the city. The park was patrolled by only two security officers, who worked for a private security company that was contracted by the city to secure the park Evidence suggested that the two guards were asleep in an adjacent building at the time of the incident.

 

While the woman was exploring the park, a youth attempted to rob her

 

using a gun. When she reached into her purse to hued over her wallet, she pulled out a Mace ejector and sprayed the assailant in the face. Startled by the Mace, the youth pulled the trigger and shot the woman in the head, lolling her. He fled into the adjoining housing development, screaming that he did not mean to do it and why did the woman spray him! He hid until he finally was convinced by family members to give himself up.

 

The attorneys for one of the defendants alleged that, had the woman not used the Mace, she might have been alive. This argument, however, was not successful. The case was very, complex and long. The litigants in the case settled with the victim's family for an undisclosed amount of money.

 

The case included a wile range of experts and was mainly argued using the totality of circumstances approach. More specific data on crimes perpetrated against out‑of‑town tourists were utilized in the case. The consultants were asked to conduct literature reviews and original research studies on the correlation between the use of Mace and homicide. No conclusive evidence was obtained. No scientific research had been done on this topic. According to the "common wisdom" of police officers (based on interviews at select polite departments in major cities), Mace seems to offer a false sense of defense or safety and may, indeed, be more of a hazard than a help. Its use could not be considered, by any stretch of the imagination, as an act of victim precipitation. This information was useful in deflating the arguments of the opposing sides.

 

A SOCIOLOGICAL IMAGINAT1ON:

SOME CONCLUDING IRKS

 

Premise liability often is difficult to evaluate. It always involves an act or event, its relationship to a particular space, and the degree to which the owner or manager of the space and the victim are, in part, responsible for the unfortunate occurrence. The ironic and debunking nature of sociological thought is aptly suited to this type of case.

 

A sociologist and criminologist imagines a world where a single act or event is embedded in a complex array of spatial, temporal, historical, and interpersonal contingencies and conditions. It is a world where causality and liability are not readily discernable but might reveal themselves through informed speculation, a willingness to dig for seemingly unrelated patterns and occurrences, and a little luck. Black and white, good and bad, and other binary styles of reasoning rarely work in this world. It is, more often than not, a gray world where no one is simply liable or innocent, but shades of both. It is, in short, a sociological world.

 

We close on a practical note. It frequently is observed that expert witnesses use the good ideas of other sociologists and criminologists found in papers, books, and journal articles to develop and argue their opinions. It has been our experience, however, that expert witnesses often are able to contribute to their disciplines.

 

Criminologists, who work as experts, often have access to potential research data that otherwise would be impossible to obtain. The results of research conducted in connection with developing a case (e.g., analysis of police reports, supplemental surveys, content analysis of documents, evaluations, outcome assessments) offer a rich source of theoretically and methodologically significant information. The work of many "experts" has not enjoyed the status of legitimacy accorded traditional academic research and, therefore, largely has been ignored on the assumption that applied research does not represent a high level of commitment to "theory and methods." Given the increased pressure placed by courts (especially since the U.S. Supreme Court decision Daubert u. Merrell Dow Pharmaceuticals, Inc. [19931) for experts to scientifically justify their positions, we feel this charge is unfounded. We suspect that the collected works of practicing criminologists is both extensive and significant in terms of its contribution to the field of criminology, and it is not easily separated from more traditional "pure" research activities.

 

NOTES

 

1. We both have a doctorate in sociology with a concentration in criminology and research methods.

 

Z. In Las Vegas, 70 percent of all premise liability cases are casino related.

 

3. The case Isaacs u. Huntington Memorial Hospital (1985) serves as the fountainhead of the totality of circumstances rule of crime foreseeability. The plaintiff; a doctor, was shot in the physician's parking lot at a major hospital in what was considered a "high" crime area. At the nearby emergency room parking lot, large

 

numbers of interpersonal crimes had occurred, and security guards patrolled the parking area. The emergency room was open around the clock and attracted a parade of drunks, drug addicts, and assorted criminal types. Isaacs was shot by as assailant

 

near his car in the physician's parking lot. The court rejected any type of prior similar crimes argument because it would, in their opinion, discourage landowners from improving their security until the first victim had been attacked (Tom on Torts 1993:357).

 

4. Local police data are not to be confused with data from uniform crime reports (UCR). Although local police data provide the basis for the UCR, it is more comprehensive and more detailed, offering specific information such as the enact time, and the district and address of the occurrence. In addition, a wider range of crimes are recorded, not just index crimes Definitions or codes associated with crimes are bate on local and state codes, not the general or standard codes used by the UCR.

 

5. In our report, we put a lot of emphasis on the prevention of domestic violence. Morally, we feel thin is as important area of crime that must be addressed. We feel it is important to include even in evaluations that target nondomestic crimes. It is important to keep in mind that domestic violence impacts the general perceptions of dangerousness held by residents of housing developments and by the public at large, who often cannot distinguish between stranger‑ or domestic‑related crimes. The prevention of domestic violence can have significant effects on overall perceptions of crime and safety.

 

6. The importance of the demographics of a community or neighborhood cannot be underestimated from a security standpoint. We have conducted social‑demographic and crime analyses of areas for developers during their planning stages. If it is found that there are a large number of urban crime risk factors at a proposed location for a business, either stricter security measures must be incorporated into the plan or the business may be relocated in a safer environment.

 

7. We are not saying that there is a relationship between mental illness or disorder and criminality per se. We realize, of course, that the two concepts are largely unrelated (e.g., Monahan and Steadman 1984). There is, however, evidence to suggest a relationship between certain types of mental disorder (e.g., sociopathy or psychopathy, child conduct disorder DSM‑III‑R, Antis II, Cluster B, 301.70) and predisposition to violence. Sums individuals have a higher base rate of violence than "normals" (e.g., Hare 1983; Hall 1987) and are overrepresented in the commission of much violent interpersonal crime including sadistic rapes, murders (particularly serial murders or murder rampages) and other unpredictable, impulsive crimes (Robins 1966; Lewis 1989; Holmes and DeBurger 1988; Voigt et al. 1994). Thus, although mental illness and crime are largely unrelated, what makes matters difficult is that they are not completely unrelated.

 

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CASES CITED

 

Daubert u. Merrell Dow Pharmaceuticals, Inc., U.S. S. Ct., No. 92‑102, 1993 WL 224478 (1993).

 

Gannilli u. Howard Johnson's Motor Lodge, Inc., 419 F. Supp. 1210, 1212 (E.D.N.Y. 1976).

 

Isaacs v. Huntington Memorial Hospital, 38 Cal. 3d 112, 211 Cal. Rptr. 356, 695 P.2d 653 (1985).

 

Lopez u. McDonald's, 193 Cal., App. 3d 495, 23, Cal. Rept. 436 (1987). Siebert u. Vic Regnier Builders, Inc., 856 P.2d 1332 (Kansas 1993).