In Jacqueline S. v. City of New York (81 N.Y.2d at 294), the Court of Appeals clarified that to establish a landlord's liability for the foreseeable danger from criminal activity, the operative proof did not have to be limited to crimes actually occurring in the specific building where the attack took place. It found that there was no requirement in either Nallan or Miller v. State of New York, that to establish foreseeability the criminal activity be at the exact location where plaintiff was injured, or that it be of the same type of criminal conduct to which plaintiff was subjected. (Id. at 294.) In Jacqueline S., the plaintiff, a resident in one of several apartment buildings in a public housing complex, was abducted and raped by an assailant in her apartment building. (Id. at 291.) The plaintiff submitted proof of drug-related crimes in her building, and that drug addicts and vagrants gained access and hung around the corridors, stairways, and roof. She also submitted proof that the police had responded to numerous reports of rapes and robberies in the complex, and that the landlord was aware that the lobby doors and the doors to utility rooms on the roofs were not equipped with locks. (Id. at 291-292.) The Court held that this proof was enough to raise a triable issue as to foreseeability, even though there was no evidence that violent crimes had occurred previously in the building where the plaintiff was raped, because there was evidence of crime in the complex, and given the landlord's conceded failure "to supply even the most rudimentary security--e.g., locks for the entrances--it was error to grant summary judgment on the question of foreseeability." (Id. at 295.)