## Facts

- James and Sarah Crinkley stayed as weekend guests at the Holiday Inn–Concord near Charlotte, North Carolina, in February 1981.
- In the two weeks before their stay, a group known as the “Motel Bandits” robbed and assaulted guests at multiple area motels.
- The motel’s assistant manager learned of the threat through news reports and a sheriff’s office contact warning the motel and offering off-duty officers for paid security.
- Management considered but declined to hire additional security.
- Shortly after arrival, the Crinkleys were attacked by armed men; the assault began outside and continued inside their room.
- James suffered a severely broken jaw and other injuries.
- Sarah (age 66), with preexisting hypertension and obesity, later suffered a heart attack about 14 months after the assault, underwent unsuccessful angioplasty, and later had bypass surgery.
- Evidence described long-term psychological effects on Sarah, including fearfulness and withdrawal; she later received psychiatric treatment and was diagnosed with PTSD.
- The property used Holiday Inn branding and presentation; the franchisor contended it did not control day-to-day operations and was not the operator.

## Issues

1. Whether the criminal assault was reasonably foreseeable such that the motel operators owed and breached a duty to take reasonable security precautions.
2. Whether the evidence permitted a jury finding that the assault proximately caused Sarah’s later heart attack and psychiatric injuries.
3. Whether the franchisor could be held liable under apparent agency based on branding and guest reliance.
4. Whether the compensatory awards were so excessive as to require a new trial or remittitur.

## Decision

- The Fourth Circuit affirmed the judgment for the Crinkleys.
- The evidence supported foreseeability and a finding that defendants negligently failed to provide adequate security despite recent similar crimes and a law-enforcement warning.
- The court upheld submitting Sarah’s heart attack and PTSD-related damages to the jury based on medical and lay testimony linking those conditions to assault-related stress and trauma.
- The court upheld liability against the franchisor on an apparent-agency theory where the property was held out as part of the Holiday Inn system and guests could reasonably believe the franchisor operated it.
- The awards ($400,000 to Sarah; $100,000 to James) were supported by the record and not excessive.

## Legal Principles

- An innkeeper or business operator may have a duty to take reasonable precautions against third-party crime when prior similar incidents and specific warnings make such attacks reasonably foreseeable.
- A foreseeable criminal attack does not automatically break causation; a jury may find negligent security to be a proximate cause when the risk materializes.
- A defendant may be liable for physical and psychological consequences of a tort, including later-occurring medical conditions, when competent evidence supports causal linkage, even if the plaintiff has preexisting vulnerabilities.
- A franchisor may be liable under apparent agency when it holds out a franchisee as part of its enterprise and a guest reasonably relies on that appearance in dealing with the property.
- A compensatory verdict will be upheld absent a showing that it is unsupported by evidence or reflects passion or prejudice.

## Conclusion

The court sustained jury findings that foreseeable criminal violence created a duty to provide reasonable security, that negligent failure to do so could support damages for both immediate injuries and later stress-related medical and psychiatric harm, and that a franchisor may be liable when its branding and public presentation create apparent agency.


Crinkley v. Holiday Inns, Inc., 844 F.2d 156 (4th Cir. 1988)