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Gress v. Lakhani Hospitality, Inc.
Illinois Appellate Court
110 N.E.3d 251 (2018)
Karla Gress (plaintiff) was a guest at a Holiday Inn owned by Lakhani Hospitality, Inc., and Mansoor Lakhani (collectively LHI) (defendants). Alhagie Singhateh, a hotel security guard and maintenance worker, slipped a narcotic into Gress’s drink in the hotel’s restaurant-lounge. Another LHI employee directed Singhateh to enter Gress’s room to repair the air conditioner knowing that Gress was intoxicated. Singhateh entered Gress’s room with a key and raped Gress while she was unconscious. Gress and her husband (the Gresses) (plaintiffs) brought a premises-liability action against LHI. The Gresses’ complaint alleged numerous instances of inappropriate and licentious conduct by Singhateh and others at the Holiday Inn. The trial court dismissed the premises-liability counts, ruling that LHI could not have reasonably foreseen that Singhateh might sexually assault an intoxicated guest if given access to her room because none of the incidents the Gresses alleged included a sexual assault by Singhateh or any other employee. The Gresses appealed, arguing that LHI created a dangerous condition by sending and giving Singhateh access to Gress’s room while she was intoxicated, especially given Singhateh’s background and the hotel’s unseemly atmosphere.
Rule of Law
Holding and Reasoning (Lavin, J.)
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