The Haggard Law Firm’s Kimberly Wald and Michael Haggard have obtained a $1 Million pre-suit policy limit settlement in a negligent security case.
On March 14, 2022, Dominique Lemons was returning to her apartment. She was a quiet neighbor, loved by all, never disturbed anyone, and kept to herself. But that tragic day she was shot and killed simply walking into her apartment. This should never have happened.
Dominique left behind three beautiful children, Jashanie, 19, Joshua 16, and Janice 15, who now battle every day the tragic and unthinkable pain of losing their mother.
“This apartment complex was extremely dangerous and the owners did nothing to protect their residents. There were no gates, no lights, no cameras, no alarms, and no security guards” says Wald.
There was an ongoing problem at this apartment complex with psychiatric and mentally unstable residents who frequently caused violent disturbances, threatening the safety and well-being of all residents, including Dominique. Although there is nothing wrong with housing these individuals, when a property owner allows these individuals to reside at their complex they must ensure that this does not pose any added or increased danger to the safety and security of other tenants. Unfortunately, the Defendants did not take any precautions whatsoever to prevent foreseeable crimes and Dominique and her family paid the ultimate price.
In just a year prior to Dominique’s murder, there were countless incidents of dangerous and violent crimes occurring on the property, including:
- July 17, 2021 – a fight in the parking lot of the apartment complex where the assailant punched the victim, grabbed her neck, and bit her on the right side of her face.
- February 4, 2021 – disturbance on the property where a mentally unstable person threatened to injure others and began acting violent towards people.
- February 14, 2021 – vehicle burglary
- February 18, 2021, the police were called for a report of criminal mischief where someone was attempting to forcibly enter a window of an apartment, shattering the windowpane.
- (AGAIN) February 18, 2021, the police were called to respond to a battery
- March 11, 2021 – police again responded to the someone responding to threats of a person charging the victim with a knife. This incident involved the same individuals from the February 4, 2021.
- May 23, 2021 – police were called to the property in reference to a neighbor dispute which involved a verbal argument.
- May 30, 2021 – police again responded because there was a “very intoxicated” resident who was banging on residents doors in the middle of the night.
- June 13, 2021 and June 22, 2021 – police were called to the property again for a disturbance involving verbal altercations.
- June 22, 2021 – physical threat of murder where the subject had a knife in his hand
July 8, 2021 – the police responded to a verbal harassment call
July 24, 2021 – police called because the same residents of apartment 3 again were causing disturbances and banging on doors demanding to be let in. Given the number of disturbances these residents caused, the defendants should have evicted these tenants for disturbing the peace and creating an unreasonably dangerous situation for the other residents, including Dominique.
On September 25, 2021 – police called for aggravated assault involving a firearm. This incident is almost identical to what happened to Dominique, except the victim survived.
November 20, 2021- police responded to reports of threats to harm with a firearm

