Landlords Must Provide California Tenants Security

“A landlord generally owes a tenant the duty, arising out of their special relationship, to take reasonable measures to secure areas under the landlord’s control against foreseeable criminal acts of third parties.” (Castaneda v. Olsher (2007) 41 Cal.4th 1205, 1213, 63 Cal. Rptr. 3d 99, 162 P.3d 610 (Castaneda), citing Sharon P. v. Arman, Ltd. (1999) 21 Cal.4th 1181, 1189-1190, 91 Cal. Rptr. 2d 35, 989 P.2d 121 (Sharon P.) [“landlord[‘s] . . . general duty of maintenance includes ‘the duty to take reasonable steps to secure common areas against foreseeable criminal acts of third parties that are likely to occur in the absence of such precautionary measures,'” italics omitted] & Ann M. v. Pacific Plaza Shopping Center (1993) 6 Cal.4th 666, 674, 25 Cal. Rptr. 2d 137, 863 P.2d 207 (Ann M.) [same].) But “even when a special relationship gives rise to an affirmative duty to protect, a court must still consider whether the [foreseeability and] policy [factors] set out in Rowland [v. Christian (1968) 69 Cal.2d 108, 112-113, 70 Cal. Rptr. 97, 443 P.2d 561 (Rowland)] warrant a departure from that duty.