A motel occupier does not owe a duty of care to a gratuitous family guest to prevent injury from the criminal acts of unknown third parties, even where there is a history of property crimes at the premises. The Modbury doctrine applies to occupier's liability claims involving criminal conduct of third parties, and the exceptions (special relationships such as employer-employee, school-pupil, bailor-bailee) are underpinned by a criterion of control. A plaintiff cannot rely on a duty of care owed to another person (such as an employee) to establish her own claim. The provision of an internal lock on a sliding door discharges any duty of care that might exist; to demand security grilles or armed guards would impose too high a standard.
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