In Kane v. Hartford Accident & Indemnity Co. (1979) 98 Cal.App.3d 350, a woman was raped on hospital premises by an employee of an independently contracted janitorial service. She joined Hartford as a defendant, alleging that Hartford was negligent in bonding the employee because it failed to investigate, discover and warn against his past criminal history. Her theory was that because bonding was a requirement of his employment, he would have been fired had Hartford refused to bond him on the basis of his past record, and therefore would have been no threat to the plaintiff. The trial court granted a nonsuit, finding the connection between Hartford's acts and the resulting injury too tenuous. The Court of Appeal affirmed, holding that the plaintiff had suffered a risk of harm which was not foreseeable by Hartford. The court stated: "Hartford had no reason to suspect that Williams represented a latent threat of physical harm to anyone. Even if it had investigated Williams' past, Hartford would have discovered that the foreseeable risk, if any, was for property-related crimes, not violent crimes to persons. Least of all did Hartford have any indication that Williams' criminal impulses had, or would, come to focus on plaintiff." ( Kane v. Hartford Accident & Indemnity Co., supra, 98 Cal.App.3d at p. 357.)