Can Landowners Reasonably Foresee Shooting Rampages?

In Haire v. Bonelli, Bonelli went on a shooting rampage at a shopping mall.  Two of the injured customers sued the mall for inadequate security.  The mall had one security guard for 85 stores.  The plaintiffs argued that the shooting was foreseeable because there were other shootings at nearby malls owned by defendants.  The court however, stated that the fact that there were “mall shootings in other locations throughout the country and an acknowledgment that such a random event could, conceivably, happen anywhere,” did not make a shooting at the mall in question foreseeable.

Most would agree that more security detail is better than less.  However, with this decision it appears that the court acknowledged that in today’s age of mall, theater and school shootouts, most shooting rampages are random and not foreseeable.  While landowners may not be in the best position to prevent massive shootings, we will follow closely to see what our legislators do to try and prevent these horrors in the future.

For any questions about this post please contact Cheryl at