HIERRO v. NEW YORK CITY HOUS. AUTH.

13478, 304286/09

123 A.D.3d 508 (2014)

998 N.Y.S.2d 365

2014 NY Slip Op 08734

ELOISA HIERRO, Respondent, v. NEW YORK CITY HOUSING AUTHORITY, Appellant.

Appellate Division of the Supreme Court of New York, First Department.

Decided December 11, 2014.


A landlord has a common-law duty to take minimal precautions to protect tenants from a third party's foreseeable criminal conduct (Burgos v Aqueduct Realty Corp., 92 N.Y.2d 544, 548 [1998]). In order to recover damages, a tenant must establish that the landlord's negligent conduct was a proximate cause of the injury (id.). Where a plaintiff alleges that a criminal attack in a building was proximately caused by a landlord's...

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