In terms of sheer volume, premises-liability cases form one of the largest subcategories within the broad spectrum of tort law. Courts are dealing with this influx of lawsuits in a variety of ways. Some courts act as gatekeepers, devising rigid tests to ensure only the most deserving cases get to a jury. Other courts are more lenient, adopting flexible tests that allow more cases to reach juries. Which approach is better is the subject of much debate. This Note will discuss Missouri’s law governing negligent security actions, its application in Hudson v. Riverport Performance Arts Centre, its policy ramifications, and competing theories.

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