Graham is a landlord who owns an apartment where Sam and several other tenants live.Graham refuses to install lights,new locks,and a security system,even though Sam and several other tenants have been burglarized repeatedly in the past two weeks.Under the modern trend of landlord liability:

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Another aspect of the trend toward increasing landlords' legal accountability is that many courts have imposed on landlords the duty to take reasonable steps to protect tenants and others on their property from foreseeable criminal conduct.Although landlords are not insurers of the safety of persons on their property,a number of courts have found them liable for injuries sustained by individuals who have been criminally attacked on the landlord's property if the attack was facilitated by the landlord's failure to comply with housing codes or maintain reasonable security.This liability has been imposed on residential and commercial landlords.

Graham Is a Landlord Who Owns an Apartment Where Sam