Pearson, P. v. Philadelphia Eagles, LLC, 220 A.3d 1154

Patrick Pearson (Cowboys fan) attended an Eagles–Cowboys game at Lincoln Financial Field wearing a Cowboys jersey; he was assaulted in a crowded men's restroom at halftime and sustained serious leg injuries requiring surgery.
Lincoln Financial Field was managed by appellants Philadelphia Eagles, LLC and Eagles Stadium Operator, LLC; stadium security was provided by contractor Apex (not a party to this appeal).
Pearson sued appellants and Apex for negligence in operating stadium security; a jury found appellants 50% causally negligent, Apex 30%, Pearson 20%, and awarded $700,000.
Appellants moved for judgment notwithstanding the verdict (JNOV); the trial court denied the motion and entered judgment for Pearson; appellants appealed.
The Superior Court concluded the record did not show appellants had notice of recurring violent assaults in restrooms or that their security program was negligently operated; absence of posted restroom guards, given rarity of restroom violence, was not negligent under governing precedent.
The Superior Court vacated the judgment, reversed the denial of JNOV, and remanded with instructions to enter judgment for appellants; other claimed trial errors were not reached.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether JNOV was required because Pearson failed to prove duty, breach, or causation	Pearson: Eagles voluntarily undertook to protect guests and breached their security program, causing his injuries	Eagles: No notice of recurring restroom violence; security program reasonable; not negligent to avoid stationing guards in restrooms	Held for Eagles: record lacked evidence of notice of recurring restroom assaults or negligent operation; JNOV granted for appellants
Other alleged trial errors (impeachment limitation; insurance references; jury instruction; timing of comparative-negligence charge)	Pearson: trial rulings were proper	Eagles: errors prejudiced jury; warrant new trial	Not reached: Superior Court reversed on JNOV ground and did not decide these issues

Feld v. Merriam, 485 A.2d 742 (Pa. 1984) (property owner who voluntarily offers security program owes reasonable-care duty in performance; not an insurer; absent negligent operation or notice of risk, no liability)
United Envtl. Grp., Inc. v. GKK McKnight, LP, 176 A.3d 946 (Pa. Super. 2017) (standard of review and grounds for JNOV)
Reason v. Kathryn’s Korner Thrift Shop, 169 A.3d 96 (Pa. Super. 2017) (discusses foreseeability and duty to business invitees under Restatement §344 comment f)
Moran v. Valley Forge Drive-In Theater, 246 A.2d 875 (Pa. 1968) (adopted Restatement §344 comment f regarding duty to anticipate third-party misconduct at public places)
Kerns v. Methodist Hosp., 574 A.2d 1068 (Pa. Super. 1990) (applied Feld principles outside landlord–tenant context)