[229]*229Opinion
GEORGE, C. J.
It is 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.” (Ann M. v. Pacific Plaza Shopping Center (1993) 6 Cal.4th 666, 674 [25 Cal.Rptr.2d 137, 863 P.2d 207] (Ann M.); see also Taylor v. Centennial Bowl, Inc. (1966) 65 Cal.2d 114, 121 [52 Cal.Rptr. 561, 416 P.2d 793] (Taylor), and cases cited.)
We granted review to address a related issue that has divided the Courts of Appeal. In Mata v. Mata (2003) 105 Cal.App.4th 1121 [130 Cal.Rptr.2d 141] (Mata), the appellate court, reversing an order granting summary judgment, held that when a bar proprietor voluntarily employs a guard on its premises, the proprietor has “assumed’ a “duty to protecf’ its patrons from criminal assault “and therefore the issue of foreseeability becomes irrelevant.” (Id., at p. 1128, italics added.) In the present case, which similarly concerns a bar at which guards (or “bouncers”) were employed, the appellate court expressly disagreed with Mata, finding no duty owed and reversing a jury verdict for plaintiff, a bar patron who was injured in a criminal attack by another patron and his companions.
As we shall explain, although we agree with the Court of Appeal’s criticism of the broad language of Mata, supra, 105 Cal.App.4th 1121, quoted ante, we nonetheless disagree with that court’s conclusion that the proprietor in this case could not properly be held liable for the injury to its patron under the circumstances presented here. Accordingly, we conclude that the judgment rendered by the Court of Appeal, reversing the trial court’s judgment in favor of plaintiff, must be reversed.
I
This case arises out of a criminal assault that took place in the parking lot of defendant Trax Bar & Grill (the bar or defendant) in Turlock, California. The evidence adduced at trial, viewed in the light most favorable to the judgment (see 9 Witkin, Cal. Procedure (4th ed. 1997) Appeal, § 359, pp. 408-410, and cases cited), is summarized below.
[230]*230On weekend nights in 1998, the bar employed two persons variously referred to throughout the trial as “security people,” “security guards,” or “bouncers.”1 One guard was stationed on a stool outside the bar, in the bar’s parking lot. The second guard, Jason Nichols, was stationed inside the bar.
The bar manager testified that the guards were large and “good strong [men]” whom the manager “thought. . . would do a good job.” He explained that he provided the guards with the T-shirts they wore (bearing the words “Trax Security” or “Security” on the back) and instructed them to (i) patrol the parking lot outside the bar to ensure that persons did not congregate or consume intoxicating beverages there, (ii) check identifications in order to keep out underage patrons, (iii) count those who entered so that occupancy did not exceed 150 persons, and (iv) not physically intervene in any altercation or attack, but instead telephone “911.” In response to a specific question by plaintiff’s counsel concerning whether the bar “had any responsibility for the safety of [its] customers in the parking lot,” the manager replied, “[t]o a certain point, yeah, to see that they got to their car.”
The bar manager explained that the local police had recommended the no-physical-intervention policy, but he conceded on recross-examination that the police could take up to 20 minutes to respond. The manager explained that one purpose of the policy was to protect the bar’s own guards, who were not trained in crowd control, from injury.
The bar manager acknowledged that at times the bar’s guards ignored the no-physical-intervention policy and personally interceded in fights between patrons, and that when the guards did so they were not disciplined for a violation of procedure. Indeed, a former guard at the Trax bar, John White (who left employment at the bar approximately one month prior to the incident here at issue), testified as an expert (on behalf of plaintiff) that the custom and practice of guards at local bars generally, and his own custom at the Trax bar, was to treat the safety of patrons as a “top priority,” and to actively and physically intervene in attacks (whether inside the bar or in an adjacent parking lot) rather than simply to telephone 911. Finally, White testified that prior to terminating his employment at the Trax bar, he advised the manager that security was inadequate on busy nights.
Plaintiff Michael Wollery Delgado and his wife Dinette Douise Wollery Delgado arrived at the Trax bar approximately 10:00 to 10:30 on a Saturday night in November 1998. Plaintiff, who stood six feet one inch tall and weighed 230 pounds, had consumed two beers earlier in the evening. After [231]*231entering the bar, and over the course of the following 60 to 90 minutes, he consumed one more beer. During this time another patron, Jacob Joseph (whom plaintiff did not know), and Joseph’s three or four companions, stared at plaintiff on numerous occasions, and plaintiff stared back at the group. There was no verbal or physical interaction between plaintiff and Joseph or his companions at that time.
Prior to midnight plaintiff had become uncomfortable as a result of the continued staring and decided to leave. Although somewhat inconsistent testimony was presented to the jury concerning the events that immediately ensued leading to plaintiff’s injuries, the jury could have found from the evidence the following: (1) plaintiff’s wife approached Nichols (the interior guard) and expressed concern that “there was going to be a fight”;2 (2) Nichols himself then observed the hostile stares between plaintiff and Joseph and his companions and concluded that a fight was imminent;3 (3) Nichols determined that, under the circumstances, it would be best to ask plaintiff and his wife to leave, and Nichols made that request;4 (4) plaintiff and his wife thereafter left the bar, but Nichols did not escort them to their car in the parking lot;5 (5) when plaintiff and his wife began to walk through the parking lot toward their car, which was parked approximately 40 feet from the bar door, the guard who earlier had been posted outside no longer was present, but 12 to 20 men were “standing” in the parking lot; (6) this situation was contrary to the bar’s policy of dispersing such gatherings; and (7) Joseph and his companions followed plaintiff into the parking lot and accosted him, and the other persons who were in the parking lot joined with Joseph in the assault.6
[232]*232Immediately after the attack, or perhaps during the course of it, the other security guard telephoned 911 to seek police assistance. The police arrested Joseph at the scene, and he subsequently was convicted of felony assault upon a plea of no contest. Plaintiff suffered a fractured skull and a subdural hematoma, was hospitalized for 16 days, and subsequently experienced adverse personality changes as well as chronic headaches.
Plaintiff filed a personal injury suit against Trax Bar and Grill, Southern Pacific Transportation Company (the landlord), and Joseph; plaintiff’s wife sued the same parties for loss of consortium. At the outset of the trial plaintiff’s wife dismissed her suit, and plaintiff dismissed the landlord as a defendant. Thereafter, following opening statements, the parties stipulated that Joseph had been convicted of a felony, had filed for bankruptcy protection, and no longer was a party to the case.
Trial continued against the Trax bar only, on a premises liability theory. The jury was instructed pursuant to BAJI No. 3.11,* *****7 concerning foreseeability and negligence; BAJI No. 3.13.1,8 concerning the duty to anticipate criminal conduct of a third person; and BAJI No. 8.23,9 concerning the duty of care [233]*233owed by the proprietor of a business.10 By a vote of nine to three the jury returned a special verdict finding that (i) defendant was negligent; (ii) defendant’s negligence was a substantial factor causing plaintiff’s injuries; and (iii) defendant was 100 percent at fault. The jury awarded economic damages of $81,391.61 (exactly $20,000 more than the amount of the medical expenses that the parties stipulated were incurred by plaintiff as a result of the physical injuries inflicted in the attack) and nothing for noneconomic damages (that is, nothing for pain and suffering). Judgment was entered accordingly. Defendant moved for a new trial, asserting that it owed no duty to protect plaintiff from assault, and that there was insufficient evidence of breach and causation. The trial court denied the motion.
Defendant appealed, contending that because there was no evidence of prior similar criminal assaults either on its premises or in the vicinity, the assault upon plaintiff was unforeseeable as a matter of law, and that as a consequence it owed no duty to provide a security guard and thus could not be held liable for plaintiff’s injuries.* 11 Plaintiff responded to this argument by asserting that defendant owed him a duty of care “because of the special relationship created by the hiring of security guards,” and that in any event defendant had a duty to protect plaintiff once plaintiff’s wife provided defendant with notice of the “potential problem prior to its occurrence.”
While the appeal was pending, the First District Court of Appeal, Division Four, issued its opinion in Mata, supra, 105 Cal.App.4th 1121. In that case (further described post, at pp. 247-248), a bar proprietor employed a guard, and while the guard was on a break a customer, after being told to leave by the proprietor, walked outside and fired gunshots through the front door of the bar, killing one person and wounding others. (105 Cal.App.4th at pp. 1125-1127.) The patron’s survivors sued the proprietor on a premises liability theory. The Court of Appeal in Mata concluded that the suit should [234]*234not be resolved in favor of the defendant proprietor on summary judgment, but instead should proceed to trial. (Id., at pp. 1129-1130.) In reaching that determination, the Court of Appeal reasoned that because the proprietor “employed a security guard . . . , and that guard was on duty” when the criminal assault and murder occurred, “[t]he duty to protect had already been assumed and therefore the issue of foreseeability becomes irrelevant.” (Id., at p. 1128; see also id., at p. 1129.)
The Court of Appeal below, responding to Mata, supra, 105 Cal.App.4th 1121, expressly disagreed with the proposition that merely because a bar proprietor employs guards or implements other similar measures, it thereby “assumes” a duty to protect its patrons while they are on the premises. The Court of Appeal below further disagreed with Mata’s conclusion that such an assumed duty renders the issue of foreseeability “irrelevant.” Instead, the Court of Appeal held that “genuine foreseeability” of the “particular criminal conduct” involved—here, an attack by up to five men, followed immediately by an attack by 12 to 20 additional men—was required in order to impose a legal duty of care upon defendant. Proceeding to apply that test, the Court of Appeal concluded that although there was evidence establishing that prior fights had erupted in the Trax bar parking lot, there was no evidence of any previous “coordinated gang attack” by “a large group of assailants lying in wait in the parking lot.” Having found no evidence of any prior similar criminal incident that would have put defendant on notice that such an occurrence reasonably might be anticipated, the Court of Appeal concluded that the attack upon plaintiff was unforeseeable and that defendant owed no duty to employ guards to protect plaintiff.
The Court of Appeal’s opinion acknowledged (i) Nichols’s testimony that plaintiff’s wife told Nichols of an impending fight involving her husband, and (ii) Joseph’s testimony to the effect that those who ultimately assisted in the attack upon plaintiff had been, in the lower court’s words, “visible and loitering in the parking lot as a group, contrary to [defendant’s] acknowledged policy of dispersing such gatherings.” The Court of Appeal, however, dismissed this evidence as “insufficient to establish a duty on the part of [defendant] to prevent or intervene in” the assault upon plaintiff. Accordingly, the Court of Appeal reversed the judgment in favor of plaintiff.
We granted review to address and resolve the conflict in these decisions of the First District and Fifth District Courts of Appeal.
II
Although “[a]s a general principle, a ‘defendant owes a duty of care to all persons who are foreseeably endangered by his conduct, with respect to all [235]*235risks which make the conduct unreasonably dangerous’ ” (Tarasoff v. Regents of University of California (1976) 17 Cal.3d 425, 434—435 [131 Cal.Rptr. 14, 551 P.2d 334] (Tarasoff); see generally Civ. Code, § 1714; Lugtu v. California Highway Patrol (2001) 26 Cal.4th 703, 716 [110 Cal.Rptr.2d 528, 28 P.3d 249], and authorities cited), it also is well established that, as a general matter, there is no duty to act to protect others from the conduct of third parties. (Tarasoff, supra, 17 Cal.3d 425, 435; see also Paz v. State of California (2000) 22 Cal.4th 550, 558 [93 Cal.Rptr.2d 703, 994 P.2d 975] (Paz); Williams v. State of California (1983) 34 Cal.3d 18, 23 [192 Cal.Rptr. 233, 664 P.2d 137] {Williams); Rest.2d Torts, § 314.)12 But as explained, post, courts have recognized exceptions to the general no-duty-to-protect rule, one of which—the “special relationship” doctrine—is dispositive in this case.13
A defendant may owe an affirmative duty to protect another from the conduct of third parties if he or she has a “special relationship” with the other person. (See 6 Witkin, Summary of Cal. Law (9th ed. 1988) Torts, §§ 858-866, pp. 220-233; 2 Dobbs, The Law of Torts (2001) §§ 317, 322-332 (Dobbs on Torts).) Courts have found such a special relationship in cases involving the relationship between business proprietors such as shopping centers, restaurants, and bars, and their tenants, patrons, or invitees. Accordingly, in Ann M., we recognized as “well established” the proposition that a proprietor’s “general duty of maintenance, which is owed to tenants and patrons, . . . include[s] the duty to take 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.” (Ann M., supra, 6 Cal.4th 666, 674, italics added; see also Kentucky Fried Chicken of Cal., Inc. v. Superior Court (1997) 14 Cal.4th 814, 819, & 823-824 [59 Cal.Rptr.2d 756, 927 P2d 1260] (Kentucky Fried Chicken) [proprietor who has reason to believe, from observation or experience, that the conduct of [236]*236another endangers an invitee has a duty to take reasonable steps to protect the invitee]; Peterson v. San Francisco Community College Dist. (1984) 36 Cal.3d 799, 806 [205 Cal.Rptr. 842, 685 P.2d 1193] [a special relationship exists between “a possessor of land and members of the public who enter in response to the landowner’s invitation”]; Taylor, supra, 65 Cal.2d 114, 121 [a business proprietor has a “duty to take affirmative action to control the wrongful acts of third persons which threaten invitees where the [proprietor] has reasonable cause to anticipate such acts and the probability of injury resulting therefrom”; further described post, at p. 241]; Rest.2d Torts, § 344.)14
A. The special-relationship-based duty to provide security guards
In a series of cases we have addressed the narrow question of when the scope of a proprietor’s special-relationship-based duty to patrons or invitees properly can be found to include a duty to provide security guards.
In Isaacs v. Huntington Memorial Hospital (1985) 38 Cal.3d 112 [211 Cal.Rptr. 356, 695 P.2d 653] (Isaacs), we suggested that a proprietor (there, a hospital) might have a duty to provide guards to protect patrons and invitees (in that case, a physician who practiced at the hospital) from criminal attacks by third parties upon the premises, so long as such an attack was reasonably foreseeable “in light of all the circumstances.” (Id., at pp. 126-129.) This formulation left open the possibility that a proprietor might have a duty to provide guards to protect against third party conduct, even in the absence of prior similar conduct putting the proprietor on notice of the need to protect against such conduct.
In Ann M., supra, 6 Cal.4th 666, we expressly retreated from the open-ended formulation set forth in Isaacs. In Ann M. the plaintiff, an employee who worked at a business located in a shopping center, was raped during business hours by a person who entered her place of employment. In [237]*237asserting premises liability against the defendant shopping center, the plaintiff alleged that the defendant’s duty to maintain common areas in a reasonably safe condition included an obligation to provide guards in those areas. On the facts there presented, we concluded that the scope of the proprietor’s duty did not include an obligation to provide such guards, and held that the trial court properly had granted summary judgment for the defendant.
We began our discussion in Ann M. by noting several basic legal propositions relating to the question of duty. We observed that the existence of a legal duty is a question of law for the court to determine (Ann M., supra, 6 Cal.4th at p. 674), that foreseeability is a “crucial factor” in determining the existence and scope of a legal duty (id., at p. 676),15 and that “[fjoreseeability, when analyzed to determine the existence or scope of a duty, is a question of law to be decided by the court” (Ann M., at p. 678). We also acknowledged the “well established” rule that commercial proprietors (because they generally stand in a special relationship with their tenants, patrons, or invitees) are required to “maintain land in their possession and control in a reasonably safe condition” and that this general duty includes taking “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.” (Ann M., at p. 674, and cases cited.)
Explicating the proper approach to foreseeability analysis in relation to a business proprietor’s duty to provide protection for patrons and invitees from third party crime, we stated in Ann M.: “[B]efore and after our decision in Isaacs, we have recognized that the scope of the duty is determined in part by balancing the foreseeability of the harm against the burden of the duty to be imposed. (Isaacs, supra, 38 Cal.3d at p. 125.) ‘ “[I]n cases where the burden of preventing future harm is great, a high degree of foreseeability may be [238]*238required. [Citation.] On the other hand, in cases where there are strong policy reasons for preventing the harm, or the harm can be prevented by simple means, a lesser degree of foreseeability may be required.” [Citation.]’ [Citation.] Or, as one appellate court has accurately explained, duty in such circumstances is determined by a balancing of ‘foreseeability’ of the criminal acts against the ‘burdensomeness, vagueness, and efficacy’ of the proposed security measures. (Gomez v. Ticor [(1983)] 145 Cal.App.3d [622,] 631 [193 Cal.Rptr. 600].)” (Ann M., supra, 6 Cal.4th at pp. 678-679.)
Turning to the plaintiff’s specific claim that the proprietor’s duty to reasonably secure the premises against foreseeable criminal acts of third parties included, in the circumstances there presented, a legal obligation to provide guards, we stated in Ann M. that although “there may be circumstances where the hiring of security guards will be required to satisfy a landowner’s duty of care, such action will rarely, if ever, be found to be a ‘minimal burden.’ The monetary costs of security guards is not insignificant. Moreover, the obligation to provide patrols adequate to deter criminal conduct is not well defined. ‘No one really knows why people commit crime, hence no one really knows what is “adequate” deterrence in any given situation.’ [Citation.] Finally, the social costs of imposing a duty on landowners to hire private police forces are also not insignificant. [Citation.] For these reasons, we conclude that a high degree of foreseeability is required in order to find that the scope of a landlord’s duty of care includes the hiring of security guards. We further conclude that the requisite degree of foreseeability rarely, if ever, can be proven in the absence of prior similar incidents of violent crime on the landowner’s premises.[16] To hold otherwise would be to impose an unfair burden upon landlords and, in effect, would force landlords to become the insurers of public safety, contrary to well-established policy in this state. [Citations].” (Ann M., supra, 6 Cal.4th 666, 678-679, italics added.)17
Thereafter, in Sharon P., supra, 21 Cal.4th 1181, we further elaborated upon the principles set forth in Ann M. In Sharon P, the plaintiff was [239]*239assaulted and raped shortly after parting her car in a dimly lighted garage located beneath the building in which she was employed. Although there had been recent robberies in a nearby bank, and assorted other crimes within a 50-block area surrounding the underground parting garage, there was no evidence of the occurrence of crimes similar to the assault upon the plaintiff in or near the parting garage—and indeed, no evidence of any crimes in the parting garage during the previous 10 years. After the plaintiff sued the owners and operators of the parting garage, the trial court granted the defendants’ motion for summary judgment. (Sharon P., at pp. 1185-1187.) The Court of Appeal, in a divided opinion, reversed on the basis that commercial underground parking structures are “inherently dangerous” and, notwithstanding the absence of prior similar incidents of assaults in or near the parting garage, a jury should be allowed to determine whether the defendant’s duty to provide reasonable security included an obligation to provide guards or other similar measures. (Id., at pp. 1187-1188.)18
We granted review in Sharon P. and ultimately reversed the Court of Appeal’s decision in that case. We found the evidence of prior crimes insufficiently similar to the violent assault upon the plaintiff to “establish a high degree of foreseeability that would justify . . . imposition of ... an obligation” on the defendants’ part “to provide security guards in their garage.” (Sharon P., supra, 21 Cal.4th at p. 1191; see also id., at p. 1195.) We also rejected, as legally unsupported and contrary to sound public policy, the Court of Appeal’s conclusion that underground parting facilities are, as a matter of law, “inherently dangerous,” and hence that those who own or control them must provide guards. (Id., at pp. 1191-1195.) Finally, we addressed the plaintiff’s contention that the defendants had an obligation to undertake other, assertedly less burdensome security measures, such as ensuring that the garage was brightly lighted and clean, activating and monitoring previously installed security cameras, and requiring existing personnel to walk periodically through the garage. (Id., at pp. 1195-1199.) We questioned whether such other measures, in reality, would be significantly less burdensome than the hiring of guards (id., at pp. 1196-1197), and applied the heightened foreseeability test: “[A]bsent any prior similar incidents or other indications of a reasonably foreseeable risk of violent criminal assaults in that location,[19] [240]*240we cannot conclude defendants were required to secure the area against such crime.” (Sharon P., at p. 1199.)20
In summary, as explained in Ann M., supra, 6 Cal.4th 666, and Sharon P., supra, 21 Cal.4th 1181, only when “heightened” foreseeability of third party criminal activity on the premises exists—shown by prior similar incidents or other indications of a reasonably foreseeable risk of violent criminal assaults in that location—does the scope of a business proprietor’s special-relationship-based duty include an obligation to provide guards to protect the safety of patrons. (Ann M., supra, 6 Cal.4th at p. 679 & fn. 7; Sharon P., supra, 21 Cal.4th at pp. 1190-1191, 1197-1198.)21
B. Other special-relationship-based duties
Even when proprietors such as those described, ante, have no duty under Ann M. and Sharon P. to provide a security guard or undertake other similarly burdensome preventative measures, the proprietor is not necessarily insulated from liability under the special relationship doctrine. A proprietor that has no duty under Ann M. and Sharon P. to hire a security guard or to [241]*241undertake other similarly burdensome preventative measures still owes a duty of due care to a patron or invitee by virtue of the special relationship, and there are circumstances (apart from the failure to provide a security guard or undertake other similarly burdensome preventative measures) that may give rise to liability based upon the proprietor’s special relationship.
For example, it long has been recognized that restaurant proprietors have a special-relationship-based duty to undertake relatively simple measures such as providing “assistance [to] their customers who become ill or need medical attention and that they are liable if they fail to act.” (Breaux v. Gino's, Inc. (1984) 153 Cal.App.3d 379, 382 [200 Cal.Rptr. 260]; see generally Rest.2d Torts, § 314A.) Similarly, a restaurant or bar proprietor also has a duty to warn patrons of known dangers (see Rest.2d Torts, § 344) and, in circumstances in which a warning alone is insufficient, has a duty to take other reasonable and appropriate measures to protect patrons or invitees from imminent or “ongoing” criminal conduct. (Kentucky Fried Chicken, supra, 14 Cal.4th 814, 823.) Such measures may include telephoning the police or 911 for assistance (e.g., Johnston v. Fontana (La.Ct.App. 1997) 610 So.2d 1119, 1121-1122 [duty of bar proprietor]), or protecting patrons or invitees from an imminent and known peril lurking in a parking lot by providing an escort by existing security personnel to a car in that parking lot. (Taylor, supra, 65 Cal.2d 114, 121-125 [duty of bar proprietor]; see generally BAJI No. 8.23, quoted ante, at fn. 9, under which the jury in this case was instructed.) Moreover, as especially relevant to the present case, California decisions long have recognized, under the special relationship doctrine, that a proprietor who serves intoxicating drinks to customers for consumption on the premises must “exercis[e] reasonable care to protect his patrons from injury at the hands of fellow guests” {Saatzer v. Smith (1981) 122 Cal.App.3d 512, 518 [176 Cal.Rptr. 68] {Saatzer)), and that such a duty “ ‘arises . . . when one or more of the following circumstances exists: (1) A tavern keeper allowed a person on the premises who has a known propensity for fighting; (2) the tavern keeper allowed a person to remain on the premises whose conduct had become obstreperous and aggressive to such a degree the tavern keeper knew or ought to have known he endangered others; (3) the tavern keeper had been warned of danger from an obstreperous patron and failed to take suitable measures for the protection of others; (4) the tavern keeper failed to stop a fight as soon as possible after it started; (5) the tavern keeper failed to provide a staff adequate to police the premises[22] and (6) the tavern keeper tolerated disorderly conditions [citations].’ ” {Saatzer, supra, 122 Cal.App.3d at p. 518; see also Slawinski v. Mocettini (1963) 217 Cal.App.2d 192, 196 [31 Cal.Rptr. 613], and authorities cited.)
[242]*242Taylor, supra, 65 Cal.2d 114, illustrates how these principles are applied. In that case the plaintiff, a female bar patron, twice was offensively propositioned by a male patron. Although the plaintiff rebuffed the male patron’s advances, she testified she felt she had no reason to fear him. (Id., at p. 118.) The bar employed a bouncer, who observed and overheard these encounters. Later, as the plaintiff prepared to leave when the bar was closing, the bouncer warned her not to “ ‘go outside because that goofball is out there.’ ” (Ibid.) The plaintiff replied that it was late and that she needed to depart for home so she later could go to work. The bouncer then walked the plaintiff to the bar door but did not escort her to her car in the parking lot. Upon arriving at her car in the lot, the plaintiff was attacked by the male bar patron and severely injured. The plaintiff sued the bar, claiming it was negligent in failing to provide her with adequate protection from a known danger of imminent criminal assault. After presentation of the evidence, the trial court issued a directed verdict for the bar. This court reversed, concluding from the evidence that the defendant’s bouncer “must have been apprised of the potential danger to plaintiff of assault by ‘the goofball’ that the bouncer’s warning did not adequately apprise the plaintiff of the imminent danger she faced and she had a right to depart from the bar when she elected to do so; and that the bouncer “could have easily protected her from the danger he apparently anticipated by simply accompanying [the] plaintiff to her car.” (Id., at pp. 123-124.) Accordingly, we held, it was a question for the jury whether the bouncer’s “mere admonition not to enter the parking lot because ‘that goofball is out there’ ” satisfied the defendant’s special-relationship-based duty to the plaintiff. (Id., at p. 124.)
III
We now apply to the case before us the principles discussed above. We shall conclude, contrary to the Court of Appeal below, that defendant owed a duty to plaintiff pursuant to the special relationship doctrine. Prior to doing so, however, we first address a preliminary point advocated by defendant.
A. Is “heightenedforeseeability” always required when a plaintiff seeks to impose a special-relationship-based duty upon a proprietor?
Defendant, supported by an amicus curiae on its behalf, asserts that a showing of heightened foreseeability as defined by Ann M. and its progeny always is required when a plaintiff seeks to impose special-relationship-based liability upon a proprietor related to the criminal conduct of a third party. In support, defendant and amicus curiae rely upon Hassoon v. Shamieh (2001) 89 Cal.App.4th 1191 [107 Cal.Rptr.2d 658] (Hassoon).
[243]*243In Hassoon a customer, the plaintiff, was inside a grocery store at night when he and the store’s employee noticed a man—known to be a drug dealer—being beaten on the sidewalk by a group of fellow drug dealers. The store’s employee rescued the victim and brought him inside while the attackers remained outside. Soon thereafter shots were fired into the store, injuring the customer, who subsequently sued the proprietors and the employee, claiming that the proprietors’ employee acted negligently in rescuing the victim and thereby exposing the customer to the ensuing gunshots fired from outside the store. (Hassoon, supra, 89 Cal.App.4th at pp. 1193-1194.)
Clearly, the facts in Hassoon did not implicate a proprietor’s possible obligation to provide guards or take other similarly burdensome action designed to prevent future crime, but instead concerned only a proprietor’s asserted duty to refrain from rescuing a crime victim in the face of unfolding criminal activity on or near the premises and from thereby putting the customer in danger. Nevertheless, in affirming summary judgment in favor of the defendants on three separate grounds,23 the Court of Appeal in Hassoon broadly stated as its first ground that “the absence of proof of prior similar incidents at defendants’ place of business is fatal to a successful damages claim in tort” and “means the shooting was not foreseeable.” (Hassoon, supra, 89 Cal.App.4th at p. 1195.) In addition, the Court of Appeal asserted that “the requirement of ‘prior similar incidents’ is ... a factual precondition to premises liability.” (Id., at p. 1196.)
This aspect of the decision in Hassoon—and the similarly broad position advanced by defendant and amicus curiae on its behalf, as well as by the dissenting opinions in this case—is facially inconsistent with our decisions in Ann M., supra, 6 Cal.4th 666, and its progeny, all of which, when articulating and applying the heightened foreseeability doctrine, expressly reaffirm the sliding-scale balancing formula articulated prior to and in our decision in Isaacs, supra, 38 Cal.3d 112, 125, under which we have recognized that, as a general matter, imposition of a high burden requires heightened foreseeability, but a minimal burden may be imposed upon a showing of a lesser degree of foreseeability. (See ante, at p. 237, quoting Ann M., supra, 6 Cal.4th at pp. 678-679, which in turn quoted and followed both Isaacs, supra, 38 Cal.3d 112, 125, and Gomez v. Ticor, supra, 145 Cal.App.3d 622, 631; Sharon P., supra, 21 Cal.4th at p. 1195 [same]; Wiener, supra, 32 Cal.4th at pp. 1146-1147 [same; described ante, at fn. 20]; see also Kentucky Fried Chicken, supra, 14 Cal.4th 814, 819.)24
[244]*244Accordingly, to the extent Hassoon v. Shamieh, supra, 89 Cal.App.4th 1191, 1195, suggests that a showing of heightened foreseeability is required in all premises liability cases—regardless of the extent of the burden sought to be imposed upon the defendant—that aspect of Hassoon is disapproved.
B. Special-relationship analysis
Turning to the application of the special relationship doctrine in the case before us, it is undisputed that defendant, a bar proprietor, stood in a special relationship with plaintiff, its patron and invitee, and hence owed a duty to undertake “reasonable steps to secure common areas against foreseeable criminal acts of third parties that [were] likely to occur in the absence of such precautionary measures” (Ann M., supra, 6 Cal.4th 666, 674) and to take such “appropriate action as is reasonable under the circumstances to protect patrons.” (Kentucky Fried Chicken, supra, 14 Cal.4th 814, 823; see also id., at p. 819; Taylor, supra, 65 Cal.2d 114, 121 [proprietor has duty “to take affirmative action to control the wrongful acts of third persons which threaten invitees”] and cases cited; Saatzer, supra, 122 Cal.App.3d at p. 518.)
To the extent plaintiff’s special-relationship-based claim rests upon an assertion that defendant was legally required to provide a guard or guards or to undertake any similarly burdensome measures, we initially must consider whether defendant was obligated to do so under Ann M. and Sharon P. In this respect, of course, plaintiff was required to demonstrate heightened foreseeability in the form of prior similar criminal incidents (or other indications of a reasonably foreseeable risk of violent criminal assaults in the bar or its parking lot—see ante, at fn. 19).
[245]*245In considering whether plaintiff made such a showing, we reject the suggestion of the Court of Appeal below that in order to establish heightened foreseeability under Ann M., plaintiff was required to produce evidence not only of prior similar criminal assaults, but of “a coordinated gang attack on an individual patron.” Heightened foreseeability is satisfied by a showing of prior similar criminal incidents (or other indications of a reasonably foreseeable risk of violent criminal assaults in that location) and does not require a showing of prior nearly identical criminal incidents. (See Claxton v. Atlantic Richfield Co. (2003) 108 Cal.App.4th 327, 339 [133 Cal.Rptr.2d 425] [plaintiff victim of a violent and racially motivated crime committed at a gas station established heightened foreseeability by demonstrating that the premises had been the scene of numerous recent violent crimes, although none of those prior crimes was a racially motivated crime].)
Although the record refers to a few prior altercations between patrons, we agree with the conclusion of the Court of Appeal below that plaintiff produced insufficient evidence of heightened foreseeability in the form of prior similar incidents or other indications of a reasonably foreseeable risk of a violent criminal assault on defendant’s premises that would have imposed upon defendant an obligation to provide any guard, or additional guards, to protect against third party assaults. But the absence of heightened foreseeability in this case merely signifies that defendant owed no special-relationship-based duty to provide guards or undertake other similarly burdensome preventative measures; it does not signify that defendant owed no other special-relationship-based duty to plaintiff, such as a duty to respond to events unfolding in its presence by undertaking reasonable, relatively simple, and minimally burdensome measures. Indeed, the record clearly establishes the existence of such a minimally burdensome duty here.
As noted earlier, the trial record contains evidence that defendant’s employee and guard, Nichols, was aware of facts that led him to conclude, at least a few minutes prior to the occurrence of the assault (and prior to plaintiff’s departure from the bar), that a fight was likely to occur between Joseph and his three or four companions and plaintiff, absent some intervention on Nichols’s part. The record also establishes that Nichols formed the opinion that in order to avoid an altercation it was necessary to separate plaintiff from Joseph and his group by removing plaintiff from the bar while simultaneously leaving Joseph and his group inside, and that in order to put that plan into action Nichols approached plaintiff and directed him to depart from the bar.
Having considered the Rowland factors (Rowland v. Christian, supra, 69 Cal.2d 108, 113, quoted ante, at fn. 15) as they apply to these circumstances, we conclude, first, that under the circumstances it was foreseeable that an [246]*246assault would occur absent separation of Joseph and his group from plaintiff. The remaining Rowland factors similarly support a determination that defendant had a special-relationship-based duty to respond to the unfolding events by taking reasonable, relatively simple, and minimally burdensome steps in order to address the imminent danger that Nichols perceived, and, specifically, in order to accomplish the separation that he had determined was necessary. Indeed, defense counsel essentially conceded this general point during oral argument before this court—responding with the words “Certainly. Certainly” to a question whether, in light of the circumstances then known to Nichols, there was “some minimal duty” on the part of defendant.25
Such minimally burdensome measures may have included, for example, Nichols attempting to maintain the separation between plaintiff and Joseph’s group that Nichols had determined was called for in order to avoid an imminent assault, by turning his attention to Joseph and his companions in order to dissuade them from following plaintiff (who, at Nichols’s direction, was departing from the bar).26 And, in the face of the continuing threat of a five-on-one altercation if Nichols were unable to dissuade Joseph and his [247]*247companions from following plaintiff outside, defendant also might have confirmed that the outside guard was at his post in the parking lot and was available, as necessary, to help maintain the desired separation between plaintiff and Joseph and his companions. (See Taylor, supra, 65 Cal.2d 114, 123-125 [duty of bar proprietor to respond to imminent criminal conduct]; Kentucky Fried Chicken, supra, 14 Cal.4th 814, 823 [restaurant proprietor has a duty to respond to ongoing conduct by taking “such appropriate action as is reasonable under the circumstances to protect patrons”]; Saatzer, supra, 122 Cal.App.3d 512, 518 [a bar proprietor’s duty to protect patrons “ ‘arises . . . when ... the tavern keeper had been warned of danger from an obstreperous patron and failed to take suitable measures for the protection of others’ ”].)27
IV
As noted at the outset of this opinion, we granted review in this matter largely in light of the conflict between the Court of Appeal opinion in this case and the earlier Court of Appeal opinion in Mata, supra, 105 Cal.App.4th 1121. To avoid similar conflict and confusion in future cases, we believe it is appropriate at this time to address the Mata decision and to explain why we, like the Court of Appeal, find some of the language and analysis of Mata to be overbroad and potentially misleading.
[248]*248In Mata, supra, 105 Cal.App.4th 1121, a bar proprietor posted a guard inside the front door of its bar and armed him with a billy club and a large flashlight. The guard was instructed to monitor the number of patrons who entered the bar so as not to exceed the room’s capacity, to inspect identifications in order to detect and keep out minors, to check customers for weapons, and to eject unruly customers and prevent certain “banned” customers from entering the bar or remaining on the premises. In addition, the guard was instructed to inform the bar proprietor when he needed to take a break, so that the proprietor could assume the guard’s responsibilities. {Id., at p. 1126.)
On the evening in question the guard on duty at the bar asked the proprietor’s brother to assume his post while he took a restroom break. During the guard’s break a customer, who previously had been banned from the bar and yet, earlier that same evening, had returned to and been ejected from the bar, returned yet again to the bar and, after again being told to leave, walked outside and immediately fired gunshots through the front door of the bar, killing one person and wounding others. {Mata, supra, 105 Cal.App.4th at pp. 1125-1127.) The surviving relatives of the patron who was killed and other injured patrons and their relatives sued the proprietor on a premises liability theory.
Overturning the trial court’s grant of summary judgment for the defendant, the Court of Appeal in Mata asserted that “Ann M. is inapposite as to [the proprietor’s liability] because [the proprietor] employed a security guard . . . , and that guard was on duty [when the criminal assault and murder occurred].” {Mata, supra, 105 Cal.App.4th at p. 1128.) The court in Mata continued, very broadly: “The duty to protect had already been assumed and therefore the issue of foreseeability becomes irrelevant.” {Ibid., italics added; see also id., at p. 1129.)
Within the context of the special relationship doctrine, this broad language is potentially misleading. Contrary to the suggestion that “the issue of foreseeability becomes irrelevant” whenever a proprietor has employed a security guard {Mata, supra, 105 Cal.App.4th at p. 1128), the foreseeability of the criminal conduct in question remains relevant to the existence and scope of a proprietor’s duty under the special relationship doctrine. For example, foreseeability remains highly relevant in determining the existence and scope of any duty, discussed, ante, to warn of dangers or to take appropriate measures to protect patrons or invitees from ongoing or imminent criminal conduct.
Based upon the language quoted, ante, it also appears that the Court of Appeal’s determination in Mata, supra, 105 Cal.App.4th 1121, that a duty existed in that case, may have been influenced by the appellate court’s understanding of a related but separate doctrine—the negligent undertaking [249]*249doctrine. Our cases establish that a volunteer who, having no initial duty to do so, undertakes to provide protective services to another, will be found to have a duty to exercise due care in the performance of that undertaking if one of two conditions is met: either (a) the volunteer’s failure to exercise such care increases the risk of harm to the other person, or (b) the other person reasonably relies upon the volunteer’s undertaking and suffers injury as a result.28 Even if the court in Mata may have been influenced by that doctrine, however, the decision’s broad language failed to recognize the important limitations and qualifications of that doctrine.
Mata indicated in expansive terms that by hiring a guard a proprietor necessarily assumes a general duty to protect its patrons. We disagree. First, the scope of any duty assumed depends upon the nature of the undertaking. (See Artiglio, supra, 18 Cal.4th 604, 614—615.) Merely because a supermarket or other similar enterprise “chooses to have a security program” that includes provision of a roving security guard does not signify that the proprietor has assumed a duty to protect invitees from third party violence. (Brown v. Schnuck Markets, Inc. (Mo.Ct.App. 1998) 973 S.W.2d [250]*250530, 535.) A store that hires a “security officer” to guard its interior “cash office” for three hours each day does not assume a duty to protect a customer who is injured in the store’s exterior parking lot by the criminal act of a third party. (See Posecai v. Wal-Mart Stores, Inc. (La. 1999) 752 So.2d 762, 764, 769 & fn. 7.) Second, as noted, ante, a defendant’s undertaking will support the finding of a duty to another only if (a) the defendant’s action increased the risk of harm to another, or (b) the other person reasonably relied upon the undertaking to his or her detriment. (Williams, supra, 34 Cal.3d 18, 23; Weissich v. County of Marin, supra, 224 Cal.App.3d 1069, 1077.) The court in Mata did not consider whether the imposition of liability in that case was consistent with these limitations.
Finally, contrary to the implications of Mata's broad language (Mata, supra, 105 Cal.App.4th at p. 1128), foreseeability remains a highly relevant factor— even in cases in which a legal duty is found (and regardless of the doctrine under which it is found). For example, even when a proprietor voluntarily has employed one or more guards and properly is found to owe a duty to patrons, foreseeability remains relevant to the fact finder’s determination of breach and causation.
V
We conclude that the Court of Appeal below erred in reversing the trial court’s judgment in favor of plaintiff on the ground that defendant owed no duty to plaintiff. Instead, as explained, ante because defendant had actual notice of an impending assault involving Joseph and plaintiff, its special-relationship-based duty included an obligation to take reasonable, relatively simple, and minimally burdensome steps to attempt to avert that danger. Whether there was sufficient evidence to support the jury’s determinations of breach of duty and causation are matters, among others, to be addressed by the Court of Appeal on remand.
The judgment of the Court of Appeal is reversed and the matter is remanded for further proceedings to permit that court to address defendant’s remaining contentions as well as the issues concerning damages raised by plaintiff in his cross-appeal.
Baxter, J., Werdegar, J., Chin, J., and Moreno, J., concurred.