Wright v. PRG Real Estate Management, Inc.
South Carolina Supreme Court
826 S.E.2d 285 (2019)
- Written by Jamie Milne, JD
Facts
Denise Wright (plaintiff) leased an apartment in a complex managed by PRG Real Estate Management, Inc. (PRG) (defendant). When Wright signed her lease, she was told that the complex had security officers on duty. Additionally, the complex’s monthly tenant newsletter referenced a phone number for supposedly paging security. In fact, the only security on site was a courtesy-officer program that offered law-enforcement tenants reduced rent for occasional service as courtesy officers. One night, Wright was abducted from a common area within the complex and robbed at gunpoint. She sued her landlord (defendant) and PRG. The circuit court granted summary judgment in favor of the landlord and PRG, holding that they did not have a duty to protect tenants from harm caused by third parties. The appellate court affirmed. Wright appealed to the South Carolina Supreme Court, arguing that although landlords did not generally have a duty to protect tenants, an exception applied in this case because the complex claimed to have security officers.
Rule of Law
Issue
Holding and Reasoning (James, J.)
Dissent (Kittredge, J.)
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