On September 20, 2018 Snochia Moseley entered the Rite Aid warehouse facility in Aberdeen, Maryland with a gun and shot and killed three people and wounded three others. Moseley was employed by Abacus Corporation, a contractor performing work at the Rite Aid facility. Plaintiffs Haissaun Mitchell, Shyhem Mitchell, and Michael Mitchell, were working for another contractor at the facility, and they subsequently brought suit against Rite Aid and Abacus for injuries they allegedly sustained as a result of the shooting incident.

After the Circuit Court granted the defendants’ motions for summary judgment, the plaintiffs appealed. The Appellate Court of Maryland affirmed. In doing so, it found that the plaintiffs had not established that the shooter’s attack was reasonably foreseeable because there were no facts that placed Rite Aid on notice that the shooter posed a threat of violence, or that Rite Aid knew or should have known that the security measures already taken at its facility created a situation that afforded a third person an opportunity to commit such a shooting.

The Appellate Court also found that Abacus could not be held liable for negligent hiring because it conducted a reasonable inquiry into the shooter’s fitness to be an employee when it hired her. Mitchell v. Rite Aid, et. al. (decided March 2, 2023).