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Crinkley v. Holiday Inns, Inc.
United States Court of Appeals for the Fourth Circuit
844 F.2d 156 (1988)
In February 1981, James and Sarah Crinkley (plaintiffs) were weekend guests at the Holiday Inn Concord, a hotel owned by Holiday Inns, Inc. (Holiday Inn) (defendant) near Charlotte, North Carolina. During the two weeks prior to the Crinkleys’ stay, guests at several local motels had been robbed and assaulted by a group called the Motel Bandits by the media. Brian McRorie, the assistant manager of the Holiday Inn Concord, learned of the Motel Bandits through the news. McRorie was also contacted by the sheriff’s office, which notified him of the threat and told him that off-duty police officers were available to serve as security personnel for a fee. McRorie asked his supervisory manager Jim Van Over about hiring extra security personnel. Van Over decided that any hiring was not justified. Subsequently, immediately after the Crinkleys arrived at the Holiday Inn Concord, they were severely beaten and threatened at gunpoint by armed men. The attack began outside the hotel and continued in the Crinkleys’ hotel room. James sustained a severely broken jaw and multiple bruises to his head and upper body. Sarah, who was 66 years old and had been under treatment for hypertension and obesity prior to the assault, suffered a heart attack 14 months after the assault. After an unsuccessful balloon angioplasty, Sarah had heart-bypass surgery. Furthermore, Sarah’s friends and family reported that her personality became much more fearful, anxious, and withdrawn after the assault. In 1984, Sarah began seeing a psychiatrist, who diagnosed her with post-traumatic stress disorder. The Crinkleys sued Holiday Inn in district court, alleging negligence due to the provision of inadequate security, and further alleging that this negligence caused the Crinkleys’ injuries. The Crinkleys presented medical evidence that Sarah’s heart attack was primarily caused by stress from the assault, that her psychological issues were caused by the assault, and that the assault was reasonably foreseeable by Holiday Inn. The jury awarded $400,000 to Sarah and $100,000 to James in compensatory damages. Holiday Inn appealed, arguing that there was insufficient evidence connecting the heart attack and psychological issues to the assault. Holiday Inn also argued that these injuries should not have been submitted to the jury as compensable items of damage.
Rule of Law
Holding and Reasoning (Phillips, J.)
Dissent (Wilkinson, J.)
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