A 19-year-old man was shot and killed during a home invasion at his family’s apartment, and the family blames the apartment complex.
The family of Patrick Hurlburt this week sued the owner and manager of The Marley at Trout River Apartments on Broward Road, claiming management failed to provide adequate security despite a history of violence there.
Police said Hurlburt was in the apartment alone Feb. 13 when several people burst in just before 6:30 p.m. and robbed the 19-year-old before shooting him. He died six days later, police said. No one has been arrested.
Police had responded to the apartment complex hundreds of times over the past three years, attorney Pedro Echarte said Thursday during a news conference with the family.
“The allegations of that complaint center around the defendants’ failure to implement a single security measure at this apartment complex, despite a very, very extensive history of crime and violent crime in particular,” Echarte said. “In simple terms, this complex was an absolute war zone. And the defendants did absolutely nothing to try to address that problem before Patrick, one of its own residents, was killed.”
The young man’s father, Joshua Hurlburt, offered somber memories of his son, whom he called “my only son, my best friend.”
“I was so proud of him. He was going to go into the Air Force,” the father said. “He really didn’t deserve this. When we moved into the apartment complex, there were signs and banners saying ‘Under new management,’ and brand new carpet and appliances. … I never thought this would happen. If anyone has any information, please reach out and let us know.”
Crimes at the apartment complex
The Haggard Law Firm filed the suit on behalf of the family against the property’s ownership and Cushman & Wakefield of Florida, which the complaint identifies as the property manager. Neither responded to requests for comment from Jacksonville Today.

The suit says there were 1,988 police calls to the apartment complex from July 1, 2023, to the February day that Hurlburt was shot. The incidents, based on Jacksonville Sheriff’s Office data, include reports of shootings, armed incidents, assaults and burglaries, as well as another fatal shooting 34 days before Hurlburt was killed.
“The defendants did absolutely nothing,” Echarte said as he pointed to a list of crimes he said occurred at the complex. “With no cameras and no access control, whoever killed Patrick came and went in unseen and completely undeterred.”
“You don’t get to collect the rent and ignore the risk,” he said. “Do the right thing. Implement the security and keep your residents and guests safe.”

This is the second lawsuit Echarte’s firm has filed against the complex over a shooting. Marvin Ousley was shot during an armed robbery attempt in the parking lot Oct. 2, 2021, when the complex was called Waters Edge. He died at the scene.
Echarte said the suit resulted in a $12 million settlement in 2025. The current owners bought the complex as the earlier lawsuit was pending, he said.







