November 3, 2023

Summerfield v. City of Inglewood

Plaintiffs’ son drove to a public park in the City of Inglewood where he was shot and killed. Plaintiffs filed a wrongful death action against the City of Inglewood. They claimed that the City created a dangerous condition because it failed to provide adequate security precautions in the park. They also claimed that two other shootings in the park between 1997 and 2021 showed that the park’s lack of security attracted criminal activity, making the area inherently dangerous. The trial court sustained the City’s demurrer, and dismissed plaintiff’s case. Plaintiffs appealed.

The Court of Appeal affirmed the dismissal. The court held that (a) the lack of park security was not a physical characteristic of the public property and thus was not actionable as a dangerous condition, and (b) two prior crimes over a 23-year period did not support plaintiffs’ claims that the City’s failure to provide security cameras created inherent or ongoing danger at the park, particularly in the absence of any statutory provision establishing the City’s liability.