In O'Hara v. Western Seven Trees Corp. (1977) 75 Cal.App.3d 798, plaintiff-tenant sought damages from her landlord for injuries she received as a result of a rape she sustained on the defendant's premises. The plaintiff alleged that the landlord had actual knowledge of several recent rapes in the apartment complex and did not advise the plaintiff of these facts but, to the contrary, specifically represented that the building was safe and that adequate security existed. The court held that where the landlord has notice that certain crimes had occurred on the premises which were likely to reoccur unless security efforts are taken, the landlord has an affirmative duty to protect the tenant by either warning the tenant of the danger or by providing adequate security against such reoccurrence. The rape occurred in the tenant's apartment. Justice Christian held that the landlord's action or failure to act was the proximate cause of the tenant's injury, as the landlord had notice of the "risk of sexual assault." Relying on Kline v. 1500 Massachusetts Avenue Apartment Corp. (D.C. Cir. 1970) 439 F.2d 477, he held that, in an urban residential context, the landlord-tenant relationship gives rise to liability under circumstances where landlords have failed to take reasonable steps to protect the tenants from criminal activity.