We obtained an affirmance by the First District Court of Appeal of a defense verdict in a negligent security action. A chef was taking garbage outside of a restaurant when he was shot and killed. The estate sued our client, the owner of the commercial building and parking lot, as well as the defendants involved in the development, design and maintenance of the retail center. The jury returned a defense verdict in favor of all defendants. The estate then appealed, arguing the trial court abused its discretion in excluding subsequent remedial measure evidence of the installation of lighting, signs and cameras in the parking lot after the shooting. The First District rejected those arguments, and affirmed the final judgments in favor of the defendants.