Do Business Owner's Have a Duty To Protect Its Patrons? As a general matter, there is no duty to protect others from the criminal conduct of third parties. (Delgado v. Trax Bar & Grill (2005) 36 Cal.4th 224, 235; see Tarasoff v. Regents of University of California (1976) 17 Cal.3d 425, 435.) Nonetheless, it is now well established that "business proprietors such as shopping centers, restaurants, and bars owe a duty to their patrons to maintain their premises in a reasonably safe condition, and that this duty includes an obligation to undertake 'reasonable steps to secure common areas against foreseeable criminal acts of third parties that are likely to occur in the absence of such precautionary measures.'" (Delgado, at p. 229; accord, Morris v. De La Torre, supra, 36 Cal.4th at p. 264; Ann M. v. Pacific Plaza Shopping Center (1993) 6 Cal.4th 666, 674 disapproved on another ground in Reid v. Google, Inc. (2010) Cal.4th This expanded duty of business owners to protect their patrons and invitees from foreseeable criminal acts is based on the "special relationship" the owner has to its customers. (See Morris v. De La Torre, supra, 36 Cal.4th at p. 269 "a defendant may owe an affirmative duty to protect another from the conduct of third parties, or to assist another who has been attacked by third parties, if he or she has a 'special relationship' with the other person".) "California decisions long have recognized, under the special relationship doctrine, that a proprietor who services intoxicating drinks to customers for consumption on the premises must 'exercise reasonable care to protect his patrons from injury at the hands of fellow guests.'" (Delgado, supra, 36 Cal.4th at p. 241.) However, a business owner has no duty to protect patrons from criminal conduct that does not take place on its own premises or in areas within its control: "A defendant cannot be held liable for the defective or dangerous condition of property which it did not own, possess, or control. Where the absence of ownership, possession, or control has been unequivocally established, summary judgment is proper." (Isaacs v. Huntington Memorial Hospital (1985) 38 Cal.3d 112, 134.)