Pandey v. Banachowski, 2011 Ohio 6830 (Ohio Ct. App. 2011)

(seller of property brought negligence action against real estate agents (defendants) for failing to secure the listed, unoccupied building; alleged negligence in leaving doors unlocked, which allowed a vandal to enter and set fire to the building; summary judgment granted to defendants; court held arson was not foreseeable when no previous vandalism occurred in the area to put the defendants on notice of criminal activity, so  no duty to safeguard the property existed; defendants’ negligence was not the proximate cause of the fire because vandals could have broken in and there was no notice of criminal activity; for same lack of notice, arsonist’s action was intervening cause, relieving defendants from liability).