William Campbell v. Orient-Express Hotels Louisiana, Inc., Windsor Court Hotel Inc. of Delaware, Windsor Court Hotel, L.L.C., Windsor Court Hotel Limited Partnership, Windsor Court Management Louisiana, Inc., Abc Security Company, and Xyz Insurance Company, 2024-C-00840

William Campbell, a guest at the Windsor Court Hotel in New Orleans, was robbed and injured in the hotel’s courtyard in the early hours of December 25, 2008.
Campbell approached an unfamiliar car occupied by two unknown women, engaged in a conversation, and twice displayed a large sum of cash before being robbed and dragged by the vehicle.
He sued the Windsor Court entities, alleging negligence and strict liability due to alleged inadequate security and unsafe premises.
The trial court granted summary judgment for defendants, finding no legal duty to prevent this specific criminal act; the appellate court reversed, but the Louisiana Supreme Court granted certiorari to clarify the duties of innkeepers regarding third-party crimes.
Evidence showed there had been no similar criminal incidents at Windsor Court in 20 years; the incident was captured via surveillance footage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Duty of Innkeeper to Protect from Third-Party Crime	Hotel owed duty to protect guests from criminal acts, especially given assurances of safety and location	Hotel is not insurer of guests against all crimes, duty is only for reasonable precautions	Innkeeper owes duty of reasonable precautions; duty exists in law, but is not absolute for all criminal acts
Foreseeability and Scope of Duty	Incident was foreseeable due to area crime and hotel’s profile; inadequate lighting/security increased risk	No similar prior incidents; Campbell’s actions (approaching unknown car, displaying cash) broke causation	The harm was not within the scope of the duty, as the incident was unforeseeable in context and due to Campbell’s actions
Adequacy of Security Measures	Lack of on-site security and poor lighting contributed to risk	Adequate staffing/security; insufficient time for guards to intervene; no duty for constant presence	Hotel’s security measures were sufficient given the absence of prior crime; no breach of duty shown
Suitability for Summary Judgment	Factual disputes over foreseeability and adequacy of precautions warranted trial	No genuine issue of material fact; Campbell could not meet evidentiary burden	No genuine issue of material fact; summary judgment for defendants reinstated

Kraaz v. La Quinta Motor Inns, Inc., 410 So. 2d 1048 (La. 1982) (establishes innkeepers have a duty to take reasonable precautions against crimes but do not insure guest safety)
Posecai v. Wal-Mart Stores, Inc., 752 So. 2d 762 (La. 1999) (foreseeability and prior incidents guide business’s duty to protect patrons from third-party crime)
Pinsonneault v. Merchants & Farmers Bank & Tr. Co., 816 So. 2d 270 (La. 2002) (reiterates foreseeability and prior incidents as critical to scope of duty)
Hill v. Lundin & Associates, Inc., 256 So. 2d 620 (La. 1972) (liability turns on "ease of association" between duty and risk encountered)
Roberts v. Benoit, 605 So. 2d 1032 (La. 1991) (clarifies scope-of-duty analysis in negligence cases)