The United States District Court for the District of Columbia held that a Plaintiff had failed to establish the foreseeability of an assault he suffered at a hotel managed by the Defendant.  The Plaintiff alleged that hotel management was negligent in maintaining security measures, as well as responding to the assault; the Court held that the Plaintiff needed to prove, among additional factors, that the criminal assault was “so foreseeable” that it was the Defendant’s  “duty to guard against it by adhering to a recognized standard of care.”  The Court held that the Plaintiff’s reliance on the surrounding area’s history of prior crime, including an assault that occurred at the hotel between 2007 and 2009, was insufficient to establish the incident in question’s foreseeability. 

Beckwith v. Interstate Mgmt. Co., No. 14-00214 (D.D.C. Mar. 4, 2015).