62 N.Y.2d 506 (1984)
When the State acts as a landlord, it has a duty to maintain minimal security measures related to a specific building, like keeping outer doors locked, when there is a foreseeable risk of criminal intrusion.
Summary
Madelyn Miller, a SUNY Stony Brook student, was raped in her dormitory after her assailant entered through unlocked doors. She sued the State, alleging negligence in its capacity as a landlord for failing to maintain adequate security. The Court of Claims ruled in her favor, but the Appellate Division reversed, viewing the claim as one for inadequate police protection. The Court of Appeals reversed the Appellate Division, holding that the State, acting as a landlord, has a duty to maintain minimal security measures in the face of foreseeable criminal intrusion, and the failure to lock the outer doors was a breach of that duty and a proximate cause of Miller’s injuries.
Facts
Madelyn Miller, a student at SUNY Stony Brook, was attacked and raped in her dormitory. The assailant gained entry through unlocked outer doors. Prior incidents, including reports of strangers in the dorm and nearby crimes, indicated a risk of criminal activity. Despite these reports and the presence of locking mechanisms, dormitory doors remained unlocked at all times. Miller herself had complained about non-residents loitering in the dorm.
Procedural History
Miller sued the State in the Court of Claims, which found the State liable as a landlord for failing to protect tenants from foreseeable criminal assaults. The Appellate Division reversed, holding that the claim was essentially for inadequate police protection, for which no special relationship existed. Miller appealed to the New York Court of Appeals.
Issue(s)
Whether the State, acting as a landlord of a state-operated college dormitory, has a duty to maintain minimal security measures, such as keeping outer doors locked, to protect tenants from foreseeable criminal intrusion.
Holding
Yes, because when the State acts in a proprietary capacity as a landlord, it is subject to the same principles of tort law as a private landlord, and this includes a duty to maintain minimal security measures in the face of foreseeable criminal intrusion.
Court’s Reasoning
The Court of Appeals distinguished between the State’s governmental function of providing police protection and its proprietary function as a landlord. While the State is generally immune from negligence claims arising from governmental functions unless a special relationship exists, it is subject to the same tort law principles as private landlords when acting in a proprietary capacity. The court stated, “As a landowner, the State ‘”must act as a reasonable [person] in maintaining his property in a reasonably safe condition in view of all the circumstances, including the likelihood of injury to others, the seriousness of the injury, and the burden of avoiding the risk”‘” (quoting Preston v State of New York, 59 N.Y.2d 997, 998). The specific act complained of – failing to lock the outer doors – fell within the State’s proprietary function as a landlord. The court found sufficient evidence to support the trial court’s conclusion that this failure was a breach of duty and a proximate cause of Miller’s rape. The Court emphasized that this ruling was about minimal security measures related to the specific building and didn’t extend to broader campus security measures that would fall under the State’s police protection capacity. Judge Kaye, in concurrence, emphasized the ruling was specific to the State’s policy of *always* leaving the doors unlocked despite reported crime, stopping short of requiring all doors to always be locked.