Ungruhe v. Blake-Riv Realty LLC

“A landlord has a common-law duty to take minimal security precautions to protect tenants and members of the public from the foreseeable criminal acts of third parties. This duty is also applicable to managing agents” (Wayburn v Madison Land Ltd. Partnership, 282 AD2d 301, 303 [2001] [internal citations omitted]). Here, defendants’ summary judgment motion was properly denied since the record presents triable issues as to whether the assault on plaintiff was foreseeable.

There was evidence of complaints by the building’s tenants of continuously broken locks on the exterior doors of the building…