In Dickinson Arms-Reo, L.P. v. Campbell, 4 S.W.3d 333, 335-36 (Tex. App.--Houston [1st Dist.] 1999, pet. filed), juveniles who had earlier attended a gang party at an apartment in the same complex murdered a tenant's guest during a carjacking on the complex property.
In a three and one-half year period, the complex had experienced 184 reported offenses. Id. at 340.
A resident who was also a part-time leasing agent at the complex had reported to higher management that many nonresidents were on the premises in the evenings, "taking over" the pool and laundry area. She considered these strangers dangerous to her and her children. Id.
An assault had occurred only five days before the carjacking/murder. Id. at 339.
Under those facts, the appellate court upheld a jury finding that the carjacking/murder was foreseeable.