California Landlords\u27 Duty to Protect Tenants from Criminals

This Comment examines the status of a California landlord\u27s duty to provide security measures for his tenant. The author analyzes and critiques recent appellate court decisions that have required prior criminal conduct on the premises as a prerequisite to holding a landlord liable in tort for criminal acts. The author argues that the focus of inquiry should be on whether the landlord has been reasonable in providing protective measures and further argues that certain minimum safety requirements should be legislatively enacted