Girardi v. San Rafael Homeowners Assn.
Plaintiffs Thomas V. Girardi and Erika Girardi (collectively, the Girardis) appeal from a summary judgment entered in favor of defendants Alta San Rafael Association (erroneously sued and served as San Rafael Homeowners Association), and Board of Directors of Alta San Rafael Association (erroneously sued and served as Board of Directors of San Rafael Homeowners Association) (collectively, the Association). The Girardis sued the Association for negligence after their home was burglarized twice. They alleged that the Association, which manages and maintains a common interest development in the Alta San Rafael neighborhood of Pasadena in which the Girardis own a house, owed the development’s homeowners a duty to keep the premises reasonably safe, and breached that duty by failing to hire a security guard, have monitored gates, and maintain street lights. The trial court granted the Association’s motion for summary judgment on the grounds that, as a matter of law, the Association owed no duty to protect homeowners’ property from theft, and even if there were such a duty, there was no causation in this case. We affirm the judgment on the ground that the Girardis failed to show a triable issue regarding causation.
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