$16 Million Negligent Security Settlement in Jacksonville Apartment Shooting Case

The Haggard Law Firm’s Kimberly Wald and Michael Haggard have obtained a $16 Million settlement on behalf of the families of multiple victims who were killed during a targeted shooting at a Jacksonville apartment complex.

Due to the terms of the settlement, the names of the parties involved remain confidential.

What Happened: A Preventable Tragedy

The fatal incident occurred when the victims were shot and killed after assailants gained unfettered access to an apartment complex. At the time of the shooting no security guards were on duty, and property access controls were insufficient. This case is another example of how inadequate safety measures and poor property management can lead to irreversible harm and loss of life. Negligent security lawsuits are often the only recourse families have to hold apartment complexes, hotels, short term rental vacations, and other commercial properties accountable when they fail to protect tenants and guests.

Trial lawyer Kim Wald

Defense Arguments vs. the Facts

During litigation, the apartment complex’s owners and property managers claimed:

  • There was no prior violent crime on the premises.
  • The vehicle gates were functioning on the night of the incident.
  • The shooting was the result of alleged gang activity involving another individual at the complex.

However, the legal team for the plaintiffs argued that property owners have a legal duty to take reasonable security measures—especially when allowing access to private residences. The failure to employ security guards, monitor guest access, and ensure the safety of visitors contributed to the preventable death of multiple innocent individuals.

National Leaders in Negligent Security Law

The Haggard Law Firm is a preeminent personal injury law firm handling negligent security cases nationwide, with a proven track record of success. The firm has recovered more than $1 Billion in verdicts and settlements for clients across the country in cases involving negligent (inadequate) security. This settlement underscores the importance of holding property owners accountable when they neglect basic safety measures that could deter violent crime. 

$12 Million Settlement in Jacksonville Negligent Security Wrongful Death Case

$12 Million settlement has been reached in a negligent security and wrongful death lawsuit filed on behalf of the estate of Marvin Ousley, a father of six who was shot and killed at the Waters Edge Apartments in Jacksonville, Florida.

The case was litigated by Pedro Echarte and Michael Haggard of The Haggard Law Firm, nationally recognized leaders in premises liability and negligent security cases. Echarte and Haggar worked with co-counsel Millicent Daniels of the Daniels Law Firm. Their work helped secure justice for the victim’s family and emphasized how property owners can be held financially accountable when they fail to prevent foreseeable crimes.

The Incident: Fatal Shooting in the Parking Lot

On October 2, 2021, Marvin Ousley was visiting family at the Waters Edge Apartments when he stepped outside to take a phone call. Eyewitnesses described a horrifying scene in which Marvin was chased through the parking lot by a gunman who yelled, “come here, boy,” shot him, and then took something from him. Marvin died at the scene.

Though no one was arrested in connection with the crime, the civil case focused on the apartment complex’s failure to provide basic, reasonable security—despite a long record of criminal activity on the premises.

Trial Attorney Michael Haggard Photo
Managing Partner Michael Haggard

Pattern of Crime and Lack of Safety

At the time of Marvin’s death, the Waters Edge Apartments were owned and operated by the defendants named in the lawsuit. Attorney Pedro Echarte and the legal team at The Haggard Law Firm uncovered evidence of:

  • A history of violent and non-violent criminal activity on the property.
  • Minimal security infrastructure—only a few surveillance cameras aimed at protecting management assets (e.g., the leasing office, laundry rooms).
  • No access control, no gated entry, and no professional security staff—only a single courtesy officer living on-site.

In sworn depositions, former employees of the defendants admitted they were unaware of the full extent of crime occurring at the complex and acknowledged that security measures were entirely inadequate.

Who Was Marvin Ousley?

Marvin was a father to six children, each with a different mother. His estate was represented by his own mother, Consuelo Hartley, who brought the wrongful death claim on behalf of her grandchildren.

The defendants attempted to use Marvin’s family structure to limit damages. But attorneys Echarte, Haggard, and Daniels effectively demonstrated through photos, videos, and testimony that Marvin had meaningful relationships with each of his children.

Overcoming the Defense’s Arguments

Defense counsel claimed that:

  • The majority of past violent crimes occurred at night, while Marvin was killed during daylight hours.
  • Most crimes had taken place over a year before the shooting.

The plaintiff’s legal team rebutted these claims by showing that the risk of crime remained high, that violent crime was foreseeable, and that the property owners had taken no meaningful action to protect residents or guests.

Landmark $12 Million Settlement

This case concluded with a $12 million settlement. Attorneys Echarte, Haggard and Daniels’ advocacy not only brought justice for Marvin’s children but also sent a clear message to property owners throughout Florida: Neglecting tenant safety comes at a cost.

About The Haggard Law Firm

Based in Coral Gables, Florida, The Haggard Law Firm is a nationally respected personal injury firm known for groundbreaking results in negligent security, drowning, wrongful death, and catastrophic injury cases.

Have You or a Loved One Been Injured Due to Negligent Security?

If you or someone you love has been the victim of a violent crime on someone else’s property, you may have legal options. Property owners and managers have a legal duty to provide reasonable security measures to protect visitors and residents.

📞 Contact our experienced personal injury attorneys today for a free consultation.

$3.54M Settlement in Florida Wrongful Death Lawsuit Over Negligent Security at Shopping Center

The Haggard Law Firm has secured a $3.54 million settlement in a wrongful death negligent security case centered around a shopping center in Central Florida. Attorney Douglas McCarron represented the family of a man who was shot and killed while after his shift at a restaurant and club within the shopping plaza in 2022. 

The victim, a hardworking young man and beloved son, left behind two grieving parents who sought justice after his tragic and preventable death. Due to confidentiality terms, the names of the parties involved in the lawsuit remain private. This case is a powerful example of how gun violence and negligent security intersect. The lawsuit alleged that the shopping center and the restaurant/club operator failed to provide adequate security—including the absence of video surveillance, security guards, or off-duty police officers—despite being in an area with a history of criminal activity.

Trial lawyer Douglas McCarron

“The lack of basic safety measures created an environment where violent crime could occur unchecked,” said McCarron. “This settlement is a step toward accountability and a reminder that property owners have a legal duty to protect the public.” 

The Haggard Law Firm is nationally recognized for its work representing victims in gun violence lawsuits, negligent security cases, and other forms of premises liability. With a focus on holding businesses and property owners accountable, the firm continues to fight for safer communities and justice for victims of preventable violence.

Common Conditions that Give Rise to a Premises Liability Case

On August 16th, 2018 The Haggard Law Firm will present Winning Case Strategies in Premises Liability, a FREE CLE Credit Seminar. The event will take place from 1 to 5pm at the Doubletree Jacksonville Riverfront. To RSVP for the seminar, email or call Stacy at slaffere@haggardlawfirm.com   305.446.5700 

This article about premises liability cases was authored by trial lawyer and Haggard Law partner Douglas McCarron who will be one of the presenters at the CLE Seminar

Common Conditions that Give Rise to a Premises Liability Case

by Douglas Mccarron

In my experience, the most common condition in any premises liability case is the lack of guardianship of the property.  In most instances, the property owner and/or manager fails to put in place policies and procedures that ensure that the premises is kept in a reasonably safe condition.  For example, in many negligent security cases it becomes obvious that the owner and management fail to do anything that assesses violent crime occurring at the property.  Without knowing what type of crime is happening, it is nearly impossible to know what type of security measures are needed.  How can the owner make decisions about access control, manned security, and surveillance cameras, if they have failed to gather the crime statistics for the property and the surrounding area?  The answer is simple, they do not know and consequently violent crime continues to victimize the property’s guests and invitees.  In slip and fall cases, many properties fail to ensure that their employees follow the internal policies and procedures to maintain the property in a safe manner.  This leads to dangerous conditions being left on the property for an unacceptable amount of time. 

If property owners simply prepare policies and procedures for their employees to follow and have appropriate supervision to ensure that the policies and procedures are being followed, then the most dangerous conditions would cease to exist.  Obviously, financial considerations come into play for the property owners.  In developing a premises liability case, it is important to discover exactly what property owners are failing to do and why they are failing to do it.  Jurors do not appreciate property owners turning a blind eye and pleading ignorance.  Jurors also do not accept that the owners do not want to put the necessary resources (money) into the property to make it safe.

 

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As an example, my partner Todd Michaels was able to secure a $2.65 million dollar verdict in a negligent security case in Clay County, Florida where the management was their residents’ AND their own worst enemy.   The facts of the case demonstrated that the property knew that there was a upswing in crime at the property.  Instead of being proactive, the property owner allowed the access control gates to remain broken for over 6 months.  The property owner’s failure caused the death of our client during a burglary attempt to his sister’s home.    This is a prime example of how juries will find for a victim in light of a property owner refusing to make their property safe.

As discussed, when preparing a premises liability case, it is extremely important to go through what policies and procedures a property owner has put into place and whether they are being followed.   Just as important is why a property owner is failing to take the reasonable steps to make sure that the property is safe.   Get all written policies and procedures as soon as possible – send written discovery requesting this information with the filing of the Complaint.  Follow this with detailed depositions of management and the property employees.  Armed with this information, it will become easy to show that the property owner and/or management dug their head in the sand and were at fault for your client’s injury or death.

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About Douglas McCarron

Partner Douglas J. McCarron is an accomplished trial lawyer with significant experience handling a wide variety of cases including negligent security, pool drowning, dram shop, and construction and auto accidents.

Doug served as an Assistant State Attorney in Miami-Dade County for four years. While there, Doug was a member of the Career Criminal Unit where he distinguished himself in over 50 trials prosecuting violent crime. Upon leaving the State Attorney’s Office in 2000, Doug began to focus on representing victims of serious and catastrophic injury.

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