The 1st District Appellate Court affirmed the decision of the Cook County Circuit judge, ruling where a plaintiff seeks to hold a defendant liable for a criminal act committed on the defendant’s property, generalized allegations of prior crimes are insufficient to demonstrate that the act in question was foreseeable or that the defendant should be held liable.

Despite a history of 20 police reports in the prior 5 ½ years, including 11 batteries, an assault 5 thefts, and three motor vehicle thefts, the lower court found that the incident was not even remotely foreseeable.