Negligent Security of Parking Garage to Prevent Crimes

In Gomez v. Ticor (1983) 145 Cal. App. 3d 622, 193 Cal. Rptr. 600, plaintiffs' decedent was killed in a parking garage when he interrupted a robbery in progress. In reversing summary judgment for the owner of the parking structure, the court noted the history of theft and vandalism in the garage, and concluded that it was at least somewhat foreseeable that a garage patron would interrupt such an act and be subject to a violent attack by the perpetrator. As balanced against the burden of providing a " 'first line of defense' " against intruders, which the court did not precisely define but concluded was minimal and did "not place an onerous burden upon defendant or society," the court held defendant had a duty to implement those minimal measures. (Id. at pp. 632-633.)