Church Security

Does Your Church Need a Security Guard?

by Richard R. Hammar

Article summary

Most churches in America are safe places. While incidents of shootings on church property are shocking, they are rare, averaging one or two per year. But because of the open-access policy of most churches, churches remain easy targets for violent acts. While we cannot prevent such acts, church leaders can take steps to manage the risk.

Just 4 days after a gunman killed eight people in a Nebraska mall in December 2007, another gunman killed two people and injured three others at a Colorado church. Earlier that day the same gunman had killed two people at a Colorado missions training facility. These events shocked the nation and sparked an intense debate within many churches over the need for security guards. This article will review recent incidents of shootings on church property, address several legal issues associated with various security measures, and conclude with an assessment of steps church leaders can take to manage the risk.

Summary of Major Church Shooting Incidents Since 1998






how resolved

possible motive

gunman a church member?

gunman made prior threats?

shooting occurred during church services?

December 2007

New Life Church, Colorado Springs, Colorado

24-year-old Matthew Murray

2 dead, 3 wounded

High-powered rifle

gunman, committed suicide when confronted by armed church member

Revenge (expelled from Arvada missions agency)




August 2007

First Congregational Church of Neosho, Missouri

52-year-old Eiken Elam Saimon

3 dead, 4 wounded

9mm semi-automatic pistol, and a small caliber handgun

gunman surrendered to police

Family argument




May 2007

First Presbyterian Church, Moscow, Idaho

36-year-old Jason Hamilton

1 dead

AK-47 and M1A assault rifles

gunman committed suicide when cornered by police





July 2006

Jewish Federation of Greater Seattle, Seattle, Washington

30-year-old Naveed Afzal Haq

1 dead, 5 wounded

2 handguns

gunman surrendered to police

Hate crime




May 2006

The Ministry of Jesus Christ Church, Baton Rouge, Louisiana

25-year-old Anthony Bell

5 dead, 2 wounded


arrested in an apartment building away from the church

Family dispute (all victims were relatives of the gunman’s estranged wife)




February 2006

Zion Hope Missionary Baptist Church, Detroit, Michigan

22-year-old Kevin Collins

2 dead


gunman died of self-inflicted wound while fleeing police

Family dispute




October 2005

Chabad Weltman Synagogue, Boca Raton, Florida

79-year-old Marc Benayer

1 dead


gunman arrested

Revenge (victim helped gunman’s ex-girlfriend obtain a restraining order against him




August 2005

Assembly of God, Sash, Texas

54-year-old Frederick Leroy Cranshaw

2 dead

9 mm semi-automatic pistol and a .38-caliber revolver

gunman committed suicide when cornered by police several miles from the church, he





July 2005

World Changers Church International, College Park, Georgia

27-year-old John Givens



police killed gunman





March 2005

Living Church of God, Brookfield, Wisconsin

44-year-old Terry Ratzmann

7 dead, 4 wounded

9mm semi-automatic pistol

gunman died of a self-inflicted wound

Depression, alcohol use, upset over a sermon, frustration over inability to find a spouse




October 2003

Turner Monumental AME Church, Atlanta, Georgia

43-year-old Shelia Chaney Wilson

2 dead


gunman died of a self-inflicted wound

Loss of job; some church members considered the shooter “mentally unstable”




June 2002

Benedictine monastery, Conception, Missouri

71-year-old Lloyd Jeffress

2 dead, 2 wounded

AK-47 assault rifle, .22 caliber rifle

gunman died of a self-inflicted wound





March 2002

Our Lady of Peace Catholic Church, Lynbrook, New York

34-year-old Peter Troy

2 dead

.22 caliber semi-automatic rifle

police arrested gunman at his home





May 2001

Greater Oak Missionary Baptist Church, Hopkinsville, Kentucky

35-year-old Fredrick Radford

2 dead


police arrested gunman at the church

Domestic dispute (one victim was his estranged wife)




September 1999

Wedgewood Baptist Church, Fort Worth, Texas

47-year-old Larry Ashbrook

7 dead, 7 wounded

9mm semi-automatic pistol

gunman died of a self-inflicted wound

Hate crime (gunman shouted anti-religious curses); friends described gunman as a paranoid loner and “very troubled”




Church Liability

Generally, property owners have no duty to protect others from the criminal acts of third parties who are not subject to their control. But there are exceptions. For example, property owners have a duty to use ordinary care to protect invitees from criminal acts of third parties if the owner knows or has reason to know of an unreasonable and foreseeable risk of harm to invitees. Persons on church property to attend religious services or other scheduled activities generally are considered invitees, whether members or visitors, since they are on the premises by reason of an actual or implicit invitation.

In deciding if criminal conduct on a landowner’s premises was foreseeable most courts have focused on the following factors:

  • Whether any criminal conduct previously occurred on or near the property.
  • how recently and how often similar crimes occurred.
  • how similar the conduct was to the conduct on the property.
  • what publicity did the media give the occurrences to indicate that the landowner knew or should have known about them.

We must consider these factors together in determining whether criminal conduct is foreseeable. The frequency of previous crimes necessary to show foreseeability lessens as the similarity of the previous crimes to the incident at issue increases. The frequent occurrence of property crimes in the vicinity is not as indicative of foreseeability as the less frequent occurrence of personal crimes on the landowner’s property itself. The court must weigh the evidence using all the factors.

Can a church be liable for deaths or injuries caused by an armed assailant as a result of a failure to employ security guards or police officers? Most churches do not employ such persons. Does this make them liable for shooting rampages that occur on their premises? No court has addressed this question in a published decision, but a few courts have addressed this question in cases involving other property owners. These cases suggest that a church has no legal duty to hire security guards except in cases of “heightened foreseeability of third party criminal activity on the premises” due to “prior similar incidents or other indications of a reasonably foreseeable risk of violent criminal assaults on church property.”

Hiring one or more security guards is an expensive practice that a church can justify only by a high degree of foreseeability that a shooting or other violent criminal act will occur on church property.

If a church decides to hire security guards, can it be liable for deaths and injuries that they cause, or fail to prevent, on the ground that the church was negligent in selecting the guards? To illustrate, assume that an armed assailant on church property shoots a woman despite the fact the church employs a security guard. The woman sues the church, claiming that the church was negligent in selecting its security guard. She points out that the guard was not a police officer, had no law-enforcement training, was not licensed, and had only minimal training in handling a firearm. Is it possible that the church is responsible for her injuries under these circumstances? While no court has addressed this question in a published decision involving a church, a few have addressed this issue in other contexts. These cases suggest that a church may be liable on the basis of negligent hiring for injuries caused by, or not prevented by, a security guard if the church failed to exercise reasonable care in investigating the competency of the guard before hiring him. The church, however, can reduce this risk by exercising reasonable care in selecting a security guard. As will be noted later, a church can best demonstrate the exercise of reasonable care by hiring only uniformed, off-duty police officers as security guards.

Churches that hire security guards may be liable for deaths and injuries caused by the negligence of their guards — even if a church did not have a legal duty to hire security guards because criminal acts on church property were not foreseeable. As one court has observed, “We do not hold that business owners owe any duty to the public to provide security services generally. We simply find that where a business owner undertakes to provide security services, he remains liable as though he directly employed the security personnel, regardless of whether they are technically employed by an independent entity.” The court noted that “the majority of jurisdictions that have considered this issue have reached the same conclusion [and] have recognized the existence of this specific nondelegable duty, either explicitly or by imposing vicarious liability on a store for the intentional torts of independently contracted security guards regardless of the nature of the employment relationship between the store and the security agency.”1

Risk Management

Courts, public figures, and law-enforcement officials have all acknowledged that no level of risk management can thwart a dedicated killer from shooting people on church premises. President Bill Clinton, following a 1999 shooting rampage in a Texas church that left 7 dead and 7 more wounded, noted that “there is nothing we can do to assure that this will never happen, but there is a lot more we can do to assure that it will happen more rarely.” Even the most stringent precautions will not prevent such incidents. To illustrate, consider a church that uses metal detectors at each entrance, and armed guards. Will these measures prevent shooting incidents from happening? No. They would not stop a dedicated assailant who is sufficiently armed.

If no level of risk management can prevent such incidents from happening, what should churches do? Church leaders need to view risk management as achieving four attainable objectives:

  • Reduce the risk that shootings and other criminal assaults will happen on church property.
  • Contain the damage if an incident should occur, through an appropriate response.
  • Ensure that the church’s precautionary measures satisfy the applicable legal duty of care. As noted previously, most courts have ruled that the level of precaution a property owner needs to take is proportional to the foreseeability that a shooting or other violent criminal act will occur on the property. The church needs to exercise the highest level of care when multiple crimes have occurred in recent years on or near church property involving shootings or other assaultive acts, or when a church receives a direct threat that a shooting or assault will occur.
  • Ensure that the church’s precautionary measures are consistent with its moral values. Most churches place a high value on human life as a result of theological and biblical principles, and may wish to adopt precautionary measures that transcend those of local businesses unconstrained by those principles.

Described below are several precautionary measures.

(1) security guards

Churches need to consider using security guards in some situations, including the following:

(a) A legal duty to employ security guards may exist because the risk of shootings or other violent crimes on church property is highly foreseeable based on the following factors described below:
  • whether any criminal conduct previously occurred on or near the property;
  • how recently and how often similar crimes occurred;
  • how similar the previous crimes were to the conduct in question; and,
  • what publicity did the media give the previous crimes to indicate that the church knew or should have known about them.
(b) The church deems the use of one or more security guards necessary to further a church’s theological and biblical principles, whether or not legally required.

As noted above, a church that uses security guards may be liable for deaths and injuries caused by the negligence of their guards based on at least two potential grounds: (1) negligent hiring; and (2) a nondelegable duty to exercise reasonable care in the protection of the public when a security guard is employed, whether or not the church had a legal duty to employ a guard. These risks make it imperative for churches that elect to use security guards to select persons of demonstrable competence. Consider the following options:

a. one or more armed, uniformed off-duty police officers during worship services and other events involving multiple persons

A church can reduce its risk of liability for injuries caused by, or not prevented by, a security guard by exercising reasonable care in selecting a security guard. A church can best demonstrate the exercise of reasonable care by hiring only uniformed, off-duty police officers as security guards since such persons:

  • are thoroughly screened before being hired as police officers;
  • receive extensive training in dealing with volatile situations;
  • receive extensive training in the use of firearms;
  • receive continuing training in the use of firearms and other job-related skills;
  • according to some courts, become on-duty police officers even while otherwise acting as private security guards when responding to criminal activity, which has the effect of insulating their employer from liability based on negligent hiring or retention for their actions; and
  • serve as a deterrent to crime because of their police uniform.

Churches considering the use of uniformed off-duty police officers need to check with the local police department regarding the recruitment of such persons as security guards, and the number of guards needed.

b. one or more uniformed, private security guards

Some churches that decide to employ security guards may opt for uniformed, private security guards who the church directly hires, or who work for a security firm that provides guards to the church pursuant to a contractual agreement. Sometimes these persons are members of the church who have nothing more than a permit to carry a concealed weapon. Churches will find it more difficult to defend against a negligent hiring claim when hiring security guards who are not police officers. But the church can reduce the risk to some degree through various means, including the following:

  • conduct a thorough criminal records check on the individual;
  • obtain several references, ideally from other institutions where the person has served as a security guard;
  • make sure the guard is licensed under state law (if possible); and
  • have the person complete a detailed application documenting all prior experience as a security guard or police officer, along with a full description of all prior law enforcement and firearms training, and any licenses or certifications the person currently has as a security guard, police officer, or firearms trainer, under state or federal law.

According to the United States Department of Labor: “Most States require that guards be licensed. To be licensed as a guard, individuals must usually be at least 18 years old, pass a background check, and complete classroom training in such subjects as property rights, emergency procedures, and detention of suspected criminals. Drug testing often is required and may be random and ongoing.”

The appropriate government authority must license guards who carry weapons, and some receive further certification as special police officers. This allows them to make limited types of arrests while on duty. Armed guard positions have more stringent background checks and entry requirements than those of unarmed guards.

An increasing number of states are making ongoing training a legal requirement for retention of licensure. Guards may receive training in protection, public relations, report writing, crisis deterrence, first aid, and specialized training relevant to their particular assignment.

The American Society for Industrial Security International has written voluntary training guidelines. The ASIS intends for these guidelines to provide regulating bodies consistent minimum standards for the quality of security services. These guidelines recommend that security guards receive at least 48 hours of training within the first 100 days of employment. These guidelines also suggest that security guards be required to pass a written or performance examination covering topics such as sharing information with law enforcement, crime prevention, handling evidence, the use of force, court testimony, report writing, interpersonal and communication skills, and emergency response procedures. In addition, they recommend annual retraining and additional firearms training for armed officers.

Security guards with little or no training, and are not licensed under state law, present the greatest risk of liability to a church or other employer as a result of injuries they inflict while responding to a crime or otherwise performing their duties, or injuries they fail to prevent.

c. using church members legally authorized to carry a concealed weapon as nonuniformed security guards

Such persons generally offer the least risk reduction of any category of security guard if they have little or no law enforcement training, and have no license as security guards under state law. Further, they do not provide the possible deterrence that accompanies a uniform, even if it is the uniform of a private security guard rather than a police officer.

d. ushers and greeters

While technically not security guards, properly trained ushers and greeters can serve a vital role in alerting the church’s crisis response team, or local law enforcement, to suspicious behavior or acts of violence when they occur. Often, such persons may be the first responders. For this reason, it is important for them to carry cell phones.

(2) technology

Like security guards, crime-fighting technologies need to be implemented as a result of either or both of the following grounds:

(a) A legal duty to install technological devices may exist because the risk of shootings or other violent crimes on church property is highly foreseeable based on the following factors described below:
  • whether any criminal conduct previously occurred on or near the property;
  • how recently and how often similar crimes occurred;
  • how similar the previous crimes were to the conduct in question; and
  • what publicity did the media give the previous crimes to indicate that the church knew or should have known about them.
(b) The use of one or more technological devices is deemed necessary to further a church’s theological and biblical principles, whether or not legally required.

In evaluating the feasibility of various technologies to prevent or reduce the risk of shootings in public schools, the United States Department of Justice noted that schools must consider the effectiveness, affordability, and acceptability of each technology. To illustrate, many church leaders would regard metal detectors at church entrances as unacceptable, even if they were affordable and effective, because they are incompatible with the concept of sanctuary and are at odds with biblical assurances of providence and divine protection. Many smaller churches cannot afford such devices.

Listed below are three different devices often used to prevent or reduce the risk of crime. In each case, church leaders need to consider the device’s effectiveness, affordability, and acceptability in evaluating its usefulness.

a. surveillance cameras

Surveillance cameras cannot prevent shootings and other violent crimes on church property, but they can act as a deterrent to crime, provide a record of what happened, allow church staff to monitor the entire church campus from a single location, and expedite a call to the police in the event of suspicious behavior.

On the downside: (1) surveillance cameras are expensive, and this disadvantage is compounded when multiple cameras are employed; (2) someone must continually check the monitors, and this removes the person from performing more active surveillance, such as visiting areas where people congregate; (3) selecting the appropriate equipment requires technical knowledge; (4) ongoing maintenance and operational support are required; (5) some individuals will challenge the need for cameras in a church; (6) persons with knowledge of the installed video system’s capabilities may not be deterred by them, and possibly could circumvent the system to their advantage or carry out their criminal acts in a different area of the church; and (7) cameras will not deter dedicated assailants, especially if they plan on killing themselves at the end of their crime spree.

b. metal detectors

Most church leaders, even in high-crime areas, consider the use of metal detectors at church entrances to be offensive to congregational members and visitors, and fundamentally incompatible with the nature of the church as a sanctuary, making their use unthinkable. As noted above, church leaders need to evaluate risk management technologies in terms of their effectiveness, affordability, and acceptability. Even if metal detectors at church entrances would be an effective deterrent to violent crime, and affordable, most church members consider them unacceptable, especially for those attending churches in low crime areas that have no history of shootings or other violent crimes on or near church property. In summary, the use of metal detectors at church entrances would be an extraordinary measure justified by only a high foreseeability of violent crime. Few churches, even in high crime areas, utilize these devices.

c. entry control technologies

Places of public accommodation can permit or deny access in four principal ways. The first and most common approach is manpower intensive, and the remaining three employ technological devices. These four approaches are:

  • A security guard controls entry; ID cards or other means of identification may be checked.
  • Electronic devices, such as a card reader, check special ID cards or badges issued to persons with permitted access. Viable card technologies for schools include bar codes or magnetic strips for card-swipe readers (such as those used for most credit cards) or passive or active radio frequency (RF) cards for proximity readers, which can validate a card several inches to several feet away (depending on the cost of the system).
  • Persons with permitted access receive a PIN number that they enter on a keypad to gain admittance.
  • A biometric device for feature recognition.
  • Measures, such as the use of metal detectors at church entrances, would not stop an armed and dedicated assailant. In addition, they would not be acceptable to most congregations since:
  • They would exclude visitors from attending church.
  • They would not accommodate members who forget their badge or card, or forget their PIN number. This could happen to any member, but the elderly would be most vulnerable to unintended exclusion.
  • Card readers do not read cards that have become demagnetized.
  • In the case of keypads and card readers, the system cannot ascertain that only a single authorized person is entering, since unauthorized persons could tailgate (follow an authorized person through the checkpoint).
  • Unauthorized persons can use stolen cards and badges.
  • The cost of a card or badge reader, or keypad system, can be substantial, especially if used at more than one entry.
  • Keypads and card readers can malfunction. The prospect of unhappy church members standing outside in the rain, unable to enter their church because of a machine malfunction, is an unpleasant but likely scenario.

Some churches use keypads or card readers during the week to restrict access to church employees.

(3) signage

Conspicuous signs at church entrances may serve many purposes. The church should not underestimate their value to security. Signs are not too expensive, but the price of not having one can sometimes be substantial. Consider the following:

  • Signs that inform persons entering a building that certain security measures are in place can provide a frontline deterrent. An outsider faced with the choice of committing a crime in a church with security warning signs or in one with no signs or other indications of self-defense will often choose the latter.
  • A church can reduce its potential liability through the use of signs. An important piece of information that a church can include on a warning sign is whether a person is monitoring the cameras. Some victims of assaults in public buildings have filed successful lawsuits, claiming that they did nothing to defend themselves because they were under the impression that, because a video camera was aimed directly at them, help would surely arrive soon. This is a common assumption. They did not realize that no one was monitoring the camera. Sample wording for a school sign regarding this particular issue could be: Warning: This facility employs video surveillance equipment for security purposes. This equipment may or may not be monitored at any time. 

(4) other measures

Unfortunately, recent tragedies in the United States have demonstrated the need for churches to be prepared to respond to shootings and other violent crimes. The United States Department of Justice has prepared the following recommendations for schools to help reduce the risk of violent crime (the word “church” is substituted for “school”).2

  • Every church needs a well-thought-out, annually updated crisis plan, with regular training for all who might be involved.
  • The crisis plan needs to assign who is in charge during different types of emergencies; who is the alternate in charge; who is called first, by whom, from where, and using what; whether the church relocates and how; what type of statement the church needs to make to the press and by whom; and who is in charge when emergency teams (fire, police, and medical) arrive on the scene. These represent a few of the specifications called for.
  • In the best of all possible situations, the church will immediately mobilize a predetermined team on the occurrence of a serious situation. Team members will know who to look to for decisions and then proceed automatically in their roles for the particular plan the church chooses to implement.
  • Crisis team members need to wear distinctive clothing and remain in locations of high visibility so others can contact them in a crisis.
  • Crisis team members need to immediately contact local law enforcement when someone reports a crisis, either on a cell phone or 2-way radio. All crisis team members need to have one or both of these devices with them at all times while on church premises.
  • Consider the use of duress alarms that anyone can activate to report a crisis. These can activate an audible alarm, or an inaudible alarm that only crisis team members can detect.
  • Be sure local law enforcement professionals, your insurance agent, and an attorney review your crisis plan.


Listed below are several conclusions based on the material presented in this article:

  • Church shootings, and other violent crimes on church premises, are rare.
  • The law imposes on any place of public accommodation, including a church, a duty to protect occupants against foreseeable criminal acts. The level of protection needs to be directly proportional to the degree of foreseeability. Many courts assess foreseeability on the basis of the following factors: (1) whether any criminal conduct previously occurred on or near the property; (2) how recently and how often similar crimes occurred; (3) how similar the previous crimes were to the conduct in question; and (4) what publicity did the media give the previous crimes to indicate that the church knew or should have known about them. If shootings or other violent crimes on church property are highly foreseeable based on these factors, a church has a heightened duty to implement measures to protect occupants from such acts.
  • Many church leaders and congregations, guided and informed by their theological values, feel compelled to take steps to protect human life from acts of violence whether or not they have a legal duty to do so.
  • In evaluating which measures to implement to discharge a legal or moral duty to protect occupants, church leaders need to consider the affordability, effectiveness, and acceptability of a measure before implementing it.
  • Church leaders need to consult with local law enforcement professionals, the church insurance agent, and legal counsel when making decisions regarding which protective measures to implement. These same persons also need to review the church’s crisis response plan.
  • Contact other churches and other places of public accommodation in your community to learn what measures they have enacted to protect occupants against shootings and other violent crimes. Examples include schools, malls, libraries, restaurants, stores, sports facilities, theatres, and concert halls. This research will help church leaders ascertain the community standard. This is an important consideration in deciding if a property owner was negligent.
  • Even the most stringent protective measures would have prevented few if any of the 15 shooting incidents on church property summarized in this article. In fact, in some of these cases, the churches had already implemented what seemed to be reasonable precautionary measures. No measures, however, will foil an armed and dedicated assailant, especially if that person plans to take his own life.
  • While it is not possible for churches to prevent acts of violence on their premises, it is possible to deter such acts in some cases, and to contain the damage and destruction when an incident erupts.

This article is excerpted from a much longer article that appeared in the March-April 2008 edition of Richard Hammar’s Church Law and Tax Report newsletter. A copy of the full article may be obtained by calling 1-800-222-1840. Copyright 2008 by Richard R. Hammar.


1. Simon v. Safeway, Inc., 2007 WL 4441194 (Ariz. App. 2007).

2. Department of Justice, Research Report: The Appropriate and Effective Use of Security Technologies in U.S. Schools.

Church Parking Lots

This article has addressed shootings and other violent crimes inside churches. Criminal acts also may occur in church parking lots. While these may include assaults, shootings, abductions, and rapes, they more often involve vandalism and property offenses. As with criminal acts occurring in church buildings, a church’s legal duty to implement risk-reducing measurers in the parking lot will be based on the foreseeability that criminal acts will occur there.

Churches have used some or all of the following measures to address this risk:

  1. Provide adequate illumination of the parking lot.
  2. Designate persons who will accompany members to their car upon request. Be sure that this option is communicated to the congregation.
  3. Install one or more wide-angle video cameras on the church roof to monitor parking areas.
  4. Have a uniformed security guard, or off-duty police officer, monitor the parking lot.

For more suggestions, church leaders should contact local law enforcement officials and the church’s insurance agent.

RICHARD HAMMAR, J.D., LL.M., CPA, Springfield, Missouri