Rodriguez by Galvan v. Oak Point Mgmt

In Rodriguez by Galvan v. Oak Point Mgmt. (87 N.Y.2d 931 [1996]), it was held that defendant had no duty to secure the front door of the residential apartment building it owned and operated in order to protect passersby from the threat of criminal actions by individuals engaging in drug-related activity in or around the building. The infant plaintiff, who had been visiting a tenant, was shot by a drug dealer after he had left the building and walked some 191 feet from the front of the building. At that point, his relationship to a building tenant was "a mere fortuity having nothing to do with the circumstances surrounding the shooting." (Id. at 932.)