The Georgia Supreme Court has considered the scope of liability for proprietors, occupiers and security contractors in negligent security premises liability cases. While many had hoped the decision would clarify the test for foreseeability in cases involving third-party criminal acts, the opinion creates more uncertainty and ambiguity as to how foreseeability can be established.

The court issued its joint ruling on June 29, collectively considering three negligent security premises liability cases: CVS Pharmacy LLC v. Carmichael, S22G0527; Welch et al. v. Pappas Restaurants Inc., S22G0617; and Welch et al. v. Tactical Security Group LLC, S22G0618.