Landlord Liability for Third Party Criminal Acts

A recent South Carolina Supreme Court opinion has sparked an important conversation about whether landlords have a duty to protect tenants from third party criminal acts.  In Wright v. PRG Real Estate Management, et. al., the tenant (Wright) was robbed and kidnapped at gunpoint by two men hiding behind overgrown shrubbery in an unlit common area of the complex. She sued the apartment complex owners, property management company, and the property manager, individually, for negligence, Wright claimed, in part, that the apartment complex voluntarily undertook a duty to provide security to residents and breached this duty. In South Carolina, landlords are generally under no duty to provide security to protect tenants from criminal acts of third parties. However, a landlord…