Linda Kay Knodle, a flight attendant then employed by Continental Air Lines, Inc., was murdered by George Patrick Murphy on November 26, 1974 in the Waikiki Gateway Hotel. John Knodle, her father, suing on his own behalf and as the administrator of her estate, brought a multi-count tort action in the Circuit Court of the First Circuit against Murphy, Continental Air Lines, and the hotel, its owners, and its operators. After default was entered against Murphy and summary judgment was awarded to Continental Air Lines,*fn1 the negligence claims against the remaining defendants were tried before a jury. The jury, on interrogatories propounded by the trial judge, returned a special verdict finding Waikiki Gateway Hotel Associates, Hyatt Corporation, Continental-Kalakaua Hotel Corp., and Northridge Industries, Inc., the hotel's owners and operators, each "had a duty to take reasonable measures to safeguard Linda Kay Knodle from the foreseeable criminal acts of third parties," but none of them "breached that duty." The plaintiff appeals from the judgment that followed, urging the trial judge erred by not permitting "evidence of all reported criminal activity at and near the hotel" to be admitted at trial, by improperly instructing the jury "on proximate causation and foreseeability," and by not granting "judgment notwithstanding the verdict or, at the least, a new trial."
