In Travelers Property Casualty Co. of American v. Pratt, No. 41,387-CW. 2006 WL 2741904 (La. App. 2 Cir. Sept. 27, 2006), a Louisiana Court of Appeal ruled that a tenant owed no duty beyond reasonable measures taken to protect her premises against criminal intruders.

Vernadette Pratt leased premises from Joseph and Patricia Costanza for a restaurant called Dette's Concessions. The restaurant shared a common wall with another business in the building, Sal's Men and Boy's Fashions.