Tracy Dawn Allen v. Traci Connolly D/ba/ Traci Connolly Insurance, State Farm Mutual Automobile Insurance Company
In this summary-judgment case, the court addresses whether there was a foreseeable risk of harm giving rise to an employer's duty to protect employees from the criminal acts of third parties. Appellant Tracy Dawn Allen challenges the trial court's summary judgment in favor of her former employer, appellee Traci Connolly d/b/a Traci Connolly Insurance. Allen, an employee, was robbed and sexually assaulted by an armed assailant at work. She alleged Connolly failed to provide a safe workplace and proper training for a security system. Connolly successfully argued in the trial court that no foreseeable risk of harm existed, and thus, no duty was owed under the Timberwalk standard. The appellate court, applying the Timberwalk analysis, found insufficient evidence of prior similar criminal activity to establish foreseeability of a violent act. Consequently, the court concluded that Allen's negligence claim against Connolly fails and affirmed the trial court's judgment.