G4S Secure Solutions USA, Inc. v. Golzar

208 So. 3d 204 (2016)

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G4S Secure Solutions USA, Inc. v. Golzar

Florida Court of Appeals
208 So. 3d 204 (2016)

Facts

Eric Owens applied for a job as a security guard with G4S Security Solutions USA, Inc. (G4S) (defendant). Owens stated on his application that he had no prior criminal convictions. Owens’s background check revealed that he had been convicted of disorderly conduct, but it did not include the details of the offense, which involved Owens peeking into an inhabited building. Without inquiring into Owens’s conviction, G4S hired him as a security guard for a gated community. While Owens was in this role, Taliya Golzar (plaintiff), a teenage girl, caught him filming her while she was undressed in her bedroom. Owens did not touch Golzar. Owens’s actions caused Golzar to suffer nightmares, anxiety, and weight gain. Golzar sued Owens for invasion of privacy and obtained a $1.3 million verdict. Golzar also sued G4S, alleging that it had negligently hired, negligently supervised, and negligently retained Owens. G4S moved for a directed verdict, arguing the Golzar’s claim was barred by the impact rule. The trial court denied the motion, and G4S appealed.

Rule of Law

Issue

Holding and Reasoning (Scales, J.)

Dissent (Shepherd, J.)

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