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Nodulski v. Vargas CA5
A commercial landlord has a general duty to maintain common areas in a reasonably safe condition. (Rowland v. Christian (1968) 69 Cal.2d 108, 119.) Failure to fulfill this duty is negligence. (Brooks v. Eugene Burger Management Corp (1989) 215 Cal.App.3d 1611, 1619.) An exception to this general rule is that a commercial landlord has no duty to protect tenants against unforeseeable criminal acts of third parties. (Castaneda v. Olsher (2007) 41 Cal.4th 1205, 1213.)

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