By Juan Cordero, Esq. — Florida Premises Liability & Negligent Security Attorney

The Jacksonville motel shooting in June 2026 — where a man was found dead in his room and JSO confirmed two suspects, one still at large — is the kind of case that looks straightforward on the surface. A man is dead. A motel failed to protect him. Someone should pay.

But in Florida in 2026, negligent security cases are not straightforward. Recent decisions from Florida's District Courts of Appeal have sharpened the foreseeability defense that property owners and their insurers use to escape liability. Defense attorneys are more aggressive than ever. And most law firms — even experienced personal injury firms — do not have the specialized knowledge to overcome those defenses.

Juan Cordero Lawyers is different. Here is why.

Every negligent security case in Florida turns on a single legal concept: foreseeability. The property owner's defense is almost always the same: "We had no reason to believe a violent crime would occur here. This was unforeseeable. We are not liable."

For years, plaintiffs' attorneys could defeat that defense with a straightforward showing of prior similar crimes on or near the property. But Florida's appellate courts — including the Third, Fourth, and Fifth District Courts of Appeal — have issued a series of opinions that have made the foreseeability analysis more demanding, more nuanced, and more fact-intensive than ever before.

The Varone v. Publix decision is the most widely discussed recent example. In that case, the court examined whether prior incidents at and around a Publix location were sufficient to establish that a violent crime was foreseeable. The decision reinforced that plaintiffs must present detailed, admissible evidence — not just a general showing that crime exists in the area.

Defense lawyers now use Varone and similar DCA opinions as a sword. They file motions for summary judgment arguing that the plaintiff cannot establish foreseeability as a matter of law. In many cases — handled by attorneys who do not specialize in this area — those motions succeed. Cases are dismissed. Families get nothing.

At Juan Cordero Lawyers, we have spent years studying these decisions, understanding their limits, and building the investigative and expert framework to defeat them.

The foreseeability defense rests on a simple argument: there was no prior notice that this specific type of crime could occur at this specific location.

Here is what defense attorneys do not want you to know: foreseeability is not limited to prior identical crimes. Florida law — properly applied — recognizes a much broader range of evidence that can establish notice.

1. The Full Crime History — On and Off the Property

We do not just pull police reports for the exact address. We pull every law enforcement call within a defined radius — typically a quarter mile to a half mile — going back three to five years. We look for:

• Prior shootings, stabbings, and assaults
• Robberies and armed robberies
• Drug arrests and narcotics activity
• Trespassing and loitering complaints
• Vehicle burglaries and thefts
• Disturbance calls and fights
• Any pattern of escalating criminal activity

Florida courts have recognized that off-property crime in the immediate vicinity is relevant to foreseeability. A motel surrounded by documented criminal activity cannot claim it had no notice of danger. We have applied this framework in cases ranging from Jacksonville hotel shootings to Miami Beach incidents to Pompano Beach gas station shootings — and the pattern is always the same: the property knew, or should have known, and did nothing.

2. The Broken Windows Framework — Gateway Crimes as Warning Signs

This is where our CPTED training becomes decisive.

Crime Prevention Through Environmental Design (CPTED) is the science of how the physical environment either enables or deters criminal activity. One of its foundational principles — rooted in the Broken Windows Theory — is that low-level disorder and gateway crimes are reliable predictors of escalating violence.

When a property has a history of:

• Shoplifting and petty theft
• Graffiti and vandalism
• Loitering and trespassing
• Drug use in common areas
• Aggressive panhandling
• Recurring disturbance calls

...those are not minor nuisances. They are warning signs that the property is becoming a target environment for more serious violence. A CPTED-trained attorney knows how to present this evidence to a jury in a way that makes the connection between disorder and eventual violence scientifically and legally compelling.

Most law firms do not have CPTED-trained attorneys. We do. That difference can be the difference between winning and losing at summary judgment. To understand the full legal framework for how these cases are built, see our guide on what a negligent security injury claim looks like in Florida.

3. The Property's Own Records

We subpoena and analyze:

• Internal incident logs and security reports
• Maintenance records showing broken lights, locks, and cameras
• Prior complaints from tenants, guests, or employees
• Communications between management and ownership about security concerns
• Insurance risk assessments flagging the property as high-risk

When a property manager sent an email to ownership six months before the shooting saying "we need more security in the parking lot" — and ownership did nothing — that is not just evidence of foreseeability. That is evidence of conscious disregard for guest safety, which opens the door to punitive damages.

4. Expert Testimony That Withstands Daubert Challenges

We work with a network of certified security professionals, former law enforcement commanders, and CPTED practitioners who can testify about:

• What security measures the property should have had in place
• How those measures would have deterred or prevented the crime
• How the property's actual security compared to industry standards
• How the physical environment of the property enabled the criminal act

Defense attorneys routinely challenge plaintiff security experts under Daubert and Florida's Frye standard. Our experts are selected specifically because their methodologies are scientifically sound and litigation-tested.

Crime Prevention Through Environmental Design (CPTED) is a multi-disciplinary approach to deterring criminal behavior through the design and management of the built environment. It is used by law enforcement agencies, urban planners, architects, and security professionals worldwide.

CPTED principles include:

• Natural Surveillance — designing spaces so that legitimate users can observe activity and potential criminals feel watched (lighting, sight lines, window placement)
• Natural Access Control — using physical design to guide people through a space and limit access to vulnerable areas (fencing, landscaping, entry points)
• Territorial Reinforcement — using design elements to signal that a space is owned, maintained, and monitored (signage, maintenance, defined boundaries)
• Maintenance — the condition of a property signals whether it is actively managed; deterioration signals abandonment and invites criminal activity

When we evaluate a hotel or motel shooting, we conduct a CPTED audit of the property. We document:

• Lighting levels in parking lots, corridors, and stairwells (measured in foot-candles against industry standards)
• Sight lines and natural surveillance opportunities that were blocked or neglected
• Access control failures — unlocked gates, broken key card systems, unmonitored entry points
• Maintenance failures that signaled the property was not actively managed
• The overall environmental conditions that made the property a target

This analysis becomes the backbone of our expert testimony and our argument to the jury: this property was not just unlucky. It was designed and managed in a way that invited crime.

Juan Cordero Lawyers is one of the very few law firms in Florida — and in the nation — where the lead attorney holds formal training in both CPTED and Victim Advocate Services.

This is not a marketing claim. It reflects years of specialized education and practice in the intersection of security science, victimology, and Florida premises liability law.

What this means for your case:

• We understand the science of crime prevention at a level that most attorneys — and most defense experts — do not
• We can identify security failures that a generalist attorney would miss entirely
• We can communicate those failures to a jury in terms they understand and find compelling
• We can anticipate and counter the defense's CPTED arguments because we know the field as well as they do
• We approach every case with a victim-centered perspective that keeps the human cost of negligence at the center of the narrative

When a defense expert takes the stand and argues that the property met industry security standards, our attorneys can cross-examine that testimony with the depth and precision that only comes from genuine expertise in the field.

Florida's District Courts of Appeal have issued a series of opinions in recent years that have reshaped the negligent security landscape. Defense attorneys cite these cases aggressively at summary judgment. Here is what you need to know:

The Third DCA's decision reinforced that plaintiffs must present specific, admissible evidence of prior criminal incidents to establish foreseeability. A general showing that crime exists in the area is not enough. The court examined whether the prior incidents at and near the Publix location were sufficiently similar in nature and proximity to put the defendant on notice. For a full analysis of this decision and what it means for victims, read our dedicated breakdown: Varone v. Publix: What Is Foreseeability in Florida Negligent Security Cases?

What defense attorneys do with this: They argue that prior incidents were not similar enough, not close enough, or not frequent enough to establish foreseeability. They move for summary judgment before the case ever reaches a jury.

How we defeat it: We build a comprehensive foreseeability record from day one — pulling every police call, every incident report, every maintenance record, and every internal communication. We present the full picture of the property's crime environment, not just a list of prior shootings. We use CPTED analysis to show that the physical conditions of the property were independently predictive of violence, regardless of the specific prior incident count.

Beyond Varone, Florida appellate courts have increasingly scrutinized:

• The similarity of prior incidents (were they the same type of crime?)
• The proximity of prior incidents (were they on the property or nearby?)
• The temporal relationship of prior incidents (how recent were they?)
• The adequacy of the plaintiff's expert (does the expert's methodology meet Daubert/Frye standards?)

Each of these is a potential chokepoint where an inexperienced attorney can lose a case that should have been won.

Only a seasoned negligent security attorney knows how to navigate every one of these chokepoints simultaneously — building a record that survives summary judgment, withstands expert challenges, and persuades a jury.

Juan Cordero Lawyers has recovered some of the largest negligent security verdicts and settlements in Florida history. See our full verdicts and results →

Our verdicts and settlements represent some of the most significant negligent security recoveries in Florida history. They were not won by accident — they were won because we knew how to establish foreseeability, how to present CPTED evidence, how to retain and defend expert witnesses, and how to tell the story of a preventable tragedy to a jury. View our full track record →

When a shooting occurs at a hotel or motel, the clock starts immediately. Here is what we do the moment you call us:

Hour 1 — Evidence Preservation We send a legal hold letter to the property demanding preservation of all surveillance footage, maintenance records, incident logs, security reports, and employee records. Surveillance footage is typically overwritten in 24–72 hours. This letter creates legal liability if the property destroys evidence after receiving it.

Hour 1–24 — Public Records Requests We file public records requests with the relevant law enforcement agency — JSO, Miami-Dade PD, Broward Sheriff's Office, or others — for every call to the property going back five years. We also request crime statistics for the surrounding area.

Hour 24–48 — Scene Documentation We send investigators to document the property — photographing lighting conditions, lock mechanisms, camera placement and coverage, access control systems, and the overall physical environment. We measure foot-candle levels in parking lots and corridors. We document every CPTED failure.

Hour 48–72 — Expert Retention We contact our network of security experts and CPTED practitioners to begin their independent evaluation of the property and the incident.

This is the foundation of a winning negligent security case. It cannot be built after the evidence is gone.

We handle negligent security cases throughout Florida — including Jacksonville, Miami, Fort Lauderdale, West Palm Beach, Boca Raton, Stuart, Port St. Lucie, Fort Pierce, Orlando, and Tampa.

Recent incidents we have covered and analyzed include the Jacksonville motel shooting (June 2026), the Jacksonville hotel shooting, the Miami Beach shooting, the Pompano Beach Citgo gas station shooting, and the Orlando apartment complex shooting. In every one of these cases, the same question applies: did the property owner know the risk, and did they fail to act?

For a broader look at how Florida hotel and motel shooting liability works, see our guide: Shot at a Florida Hotel or Motel? The Property May Be Liable.

If your loved one was shot, assaulted, or killed at a Florida hotel, motel, apartment complex, parking lot, or any other property, do not hire a generalist personal injury firm and hope for the best. Hire attorneys who have spent their careers mastering this specific area of law — attorneys who are CPTED-trained, Victim Advocate-certified, and have the verdicts to prove they know how to win.

We handle all negligent security cases on a contingency fee basis: you pay nothing unless we win.

Call or text anytime:

📞 305-525-8957 — Miami & Statewide 📞 772-227-0577 — Treasure Coast

Juan Cordero is a Florida premises liability and negligent security attorney with over 26 years of experience. He is CPTED-trained, holds certification in Victim Advocate Services, and serves as an Adjunct Professor of Law at Indian River State College. He has recovered over $100 million for injured clients throughout Florida.

The information in this article is for general informational purposes only and does not constitute legal advice. Reading this article does not create an attorney-client relationship.

Related Reading:

• What Is Negligent Security and When Can You Sue in Florida?
• Negligent Security Injury Claim: Florida Victim's Guide
• Negligent Security Lawyer in Florida: When Property Owners Are Liable
• Varone v. Publix: What Is Foreseeability in Florida Negligent Security Cases?
• Shot at a Florida Hotel or Motel? The Property May Be Liable
• Jacksonville Motel Shooting: 1 Shooter Found, 1 Still Sought by JSO
• Jacksonville Hotel Shooting: What Families Need to Know
• Miami Beach Shooting: When Could a Property Owner Be Liable?
• Pompano Beach Gas Station Shooting: Property Owner Liability
• Orlando Apartment Complex Shooting: When Can Victims Sue?

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• Fort Lauderdale Negligent Security Lawyer — Serving Broward County
• Orlando Negligent Security Lawyer — Serving Central Florida
• Jacksonville Negligent Security Lawyer — Serving Northeast Florida
• Tampa Negligent Security Lawyer — Serving the Tampa Bay area
• Florida Hotel and Motel Shooting Liability — Case study
• Our Verdicts and Settlements — $28.9M+ in negligent security recoveries