Richardsonv.Thunder, LLC
During Fort Valley State University’s 2021 homecoming week, multiple shooters opened fire at an annual block party hosted by the Omega Psi Phi chapter at its longtime house, wounding freshman Megan Jackson and killing Tyler French. Jackson and French’s family sued the national fraternity and Thunder, LLC, the alumni-owned company that owned the property, for premises liability, negligent supervision, and nuisance, and the trial court granted summary judgment to the defendants. The Court of Appeals of Georgia held that the plaintiffs failed to create a jury question on whether the shootout was reasonably foreseeable, so neither defendant owed a duty to protect partygoers from it. Applying Georgia CVS Pharmacy v. Carmichael, the court found that earlier parties had produced only occasional fistfights and a few police calls for crowd control or disorderly conduct, with no weapons, injuries, or arrests, and that those incidents were not substantially similar to a multi-shooter shooting. Nothing else suggested danger: there was no evidence of a high-crime area or of guests with violent histories, witnesses described a heavy police presence and nothing alarming before the shots, and treating any large party with alcohol as foreseeably violent would make hosts insurers of guest safety. The same lack of foreseeability defeated the negligent-supervision claims against the national fraternity and the claims against Thunder, and the nuisance challenges were abandoned for lack of argument. The court noted that Georgia’s 2025 negligent-security statutes did not apply because the claims arose before their effective date.
Loading published copy…

