Tenant appreciation events, community socials, and holiday gatherings are popular ways for landlords and property managers to foster goodwill. A well-run event can strengthen relationships, improve retention, and create a sense of community. But these gatherings also raise an important question: what liability risks does a landlord face when inviting tenants—and sometimes the public—onto the property?
The Florida case Coleman v. Via Entertainment, LLC, 50 Fla. L. Weekly D2045a (Fla. 5th DCA 2025) sheds light on this issue. While the landlord-equivalent in the case was not held liable for a tragic accident following one of its events, the ruling provides a roadmap for understanding when liability is likely and how landlords can protect themselves when hosting tenant functions.
The Case in Brief: What Happened in Coleman
Via Entertainment hosted a recurring late-night series called ‘Hang Out Fridays.’ At the March 9, 2018 event, attendees were dismissed early and funneled into the parking lot. As one guest, Jarvis Coleman, walked toward his car, tragedy struck.
A driver waiting in a long line of vehicles put his truck in park and leaned outside the driver’s side door. In that instant, the passenger shifted the truck into drive and hit the gas. The truck lurched forward, hitting Coleman and fatally injuring another pedestrian. The passenger later pled guilty to vehicular homicide.
Coleman sued Via, claiming it was negligent for failing to have a traffic control plan or personnel in place to direct cars and pedestrians after the event. The trial court granted summary judgment for Via, and the appellate court affirmed. The court held that the bizarre criminal conduct of the passenger was unforeseeable and therefore broke the chain of causation.
The ruling demonstrates a key principle: landlords are not insurers against every possible accident, especially freak events that no reasonable person could anticipate; but landlords still face liability risks any time they invite people to their event or onto their property.
Lesson 1: Foreseeability Defines the Scope of Liability
The foundation of premises liability law is foreseeability. A landlord owes a duty of reasonable care to tenants and guests, but only for harms that could reasonably be anticipated. This means landlords are not expected to prevent every bizarre or random event, but they are expected to anticipate and address the risks that are common in human experience.
In Coleman v. Via Entertainment, the court emphasized that a passenger suddenly flooring the accelerator while the driver leaned out of the vehicle was a “freakish and improbable” event. No prudent property owner could have predicted it. The case highlights the legal line: landlords are responsible for the foreseeable, not the fantastical.
For landlords, examples include:
- Foreseeable risks:
- Slips and falls due to wet floors, broken pavement, or poor lighting.
- Overcrowding that leads to pushing, shoving, or trampling.
- Intoxicated guests leaving the premises and causing harm.
- Traffic congestion in parking areas, especially after large gatherings.
- Lack of security presence at an event where alcohol is served.
- Unforeseeable risks:
- Bizarre or criminal acts with no history or warning, such as a guest suddenly attacking someone without prior indication of risk.
- Random, freak accidents like a passenger—not the driver—suddenly accelerating a car.
Practical Tasks to Reduce Liability for Foreseeable Risks
- Lighting and Visibility
- Conduct a lighting audit before the event; replace bulbs and repair fixtures.
- Use portable floodlights for outdoor events or parking lots.
- Ensure all entrances, exits, and walkways are illuminated.
- Slip, Trip, and Fall Prevention
- Place floor mats at entrances and monitor for spills during events.
- Mark uneven pavement or steps with reflective tape.
- Assign staff to periodically walk the premises during the event to identify hazards.
- Crowd Management
- Set clear maximum occupancy limits and enforce them.
- Arrange furniture or barriers to guide foot traffic and prevent bottlenecks.
- Train staff or volunteers on safe crowd control practices.
- Alcohol and Intoxication
- If serving alcohol, hire licensed bartenders trained in responsible service.
- Provide food and non-alcoholic beverages to reduce overconsumption.
- Arrange transportation options (rideshare partnerships, designated driver programs).
- Traffic and Parking Safety
- Create a traffic flow plan with clear entry and exit routes.
- Use cones, barricades, or signage to separate pedestrian areas from vehicle lanes.
- Hire attendants or off-duty officers to manage traffic in larger parking lots.
- Security and Safety Personnel
- Consider hiring security guards for larger or higher-risk events.
- Position personnel at entrances, exits, and gathering points.
- Provide radios or phones for rapid response to incidents.
- Pre-Event Safety Walkthrough
- Inspect the entire property the day of the event using a checklist.
- Document conditions with photos before the event begins.
- Correct hazards immediately and record any corrective measures taken.
Takeaway: Landlords should focus on risks that are predictable in ordinary experience and implement practical, documented safety measures to mitigate them. Courts will not impose liability for freak accidents no prudent property owner could anticipate, but they will look closely at whether the landlord took reasonable steps to prevent foreseeable harm.
Lesson 2: Intervening Criminal Acts Can Break the Chain of Liability
Another key legal principle is that an unforeseeable criminal act by a third party may cut off a landlord’s liability. In other words, if a tenant or guest’s independent, unpredictable misconduct directly causes an injury, the landlord may not be held responsible.
In Coleman, the passenger’s reckless conduct—not Via’s event planning—was deemed the true cause of the injury. The criminal act broke the legal chain of causation.
For landlords:
- If a fight breaks out at an event where alcohol is served, courts may ask whether violence was foreseeable (based on prior incidents or lack of security).
- If, however, an isolated, random act of violence occurs with no prior warning, liability is less likely.
Takeaway: While landlords must take reasonable precautions, the law recognizes limits. Random and unforeseeable criminal acts are generally not your responsibility.
Lesson 3: Risk Planning and Event Management Are Still Essential
Even though Via won in Coleman, the ruling should not be read as a free pass. The court’s decision turned on the highly unusual facts. If the harm had been foreseeable—such as intoxicated drivers in a congested parking lot—Via might have been held liable.
For landlords:
- Anticipate and plan for predictable risks when hosting events.
- Consider traffic flow, pedestrian safety, crowd size, and alcohol consumption.
- Provide adequate lighting, clear signage, and emergency exits.
- For larger gatherings, hire off-duty police or licensed security officers.
Takeaway: landlords who take proactive steps to minimize foreseeable dangers mitigate and even avoid liability. A written safety plan shows diligence and foresight.
Lesson 4: Landlords Still Owe a Duty of Care
Even though Via was not liable in this case, landlords still have a non-delegable duty to keep common areas reasonably safe. This duty intensifies when landlords host events that invite tenants and outsiders onto the property.
For landlords:
- Treat event areas—especially parking lots, walkways, and stairwells—as high-risk zones requiring extra attention.
- Inspect these areas before, during, and after events.
- Repair or block off any hazards (e.g., broken pavement, inadequate lighting).
Takeaway: Your duty of care never goes away. Hosting events expands the number of people on-site, and with it, your responsibility to ensure safety.
Lesson 5: Insurance and Contracts Are Critical Protection Tools
Even if a landlord is ultimately found not liable, the defense costs can be significant. Insurance and contractual protections are essential risk-management tools.
For landlords:
- Review your commercial general liability (CGL) policy to ensure it covers tenant or community events.
- If hiring vendors, caterers, or entertainers, require certificates of insurance and indemnity clauses.
- Consider special event liability coverage for larger functions.
Takeaway: A single accident could cost tens of thousands in legal fees. Proper insurance ensures you’re covered, even if liability is ultimately denied.
Lesson 6: Documentation Is Critical
In any negligence lawsuit, courts examine whether the landlord took reasonable precautions. Documentation is the strongest way to prove diligence.
For landlords:
- Maintain written event safety policies.
- Document lighting inspections, parking lot checks, and security arrangements.
- Keep photos, checklists, and correspondence related to safety efforts.
Takeaway: If litigation arises, your best defense is a clear paper trail showing that you anticipated risks and took reasonable steps to prevent harm.
Practical Steps for Landlords Hosting Tenant Events
- Conduct a safety walk-through before every event.
- Post clear signs for parking and pedestrian flow.
- Hire licensed security for larger gatherings.
- Ensure adequate lighting in all common areas.
- Maintain incident logs and safety checklists.
- Review insurance coverage with your agent.
- Keep records of safety measures and vendor agreements.
Conclusion
The Coleman v. Via Entertainment case reassures landlords that they are not expected to predict or prevent freak accidents caused by bizarre, unforeseeable criminal acts, but it also underscores the importance of planning, documentation, and insurance.
For landlords and property managers, the message is clear: you are not an insurer of tenant safety, but you are responsible for addressing foreseeable risks. Hosting tenant events can be a valuable way to build community, but those events should always be paired with proactive safety measures and clear documentation.

