Doe acknowledges that the landlord's duty under O.C.G.A. § 51-3-1 to keep safe those portions of the leased premises designated as common areas in which the landlord has reserved a qualified right of possession does not extend to the leased areas of the premises over which the tenant has exclusive possession and control. Stephens v. Clairmont Center, 230 Ga. App. 793, 794-795 (2) ( 498 S.E.2d 307) (1998); Gale v. North Meadow Assoc., 219 Ga. App. 801, 802-803 ( 466 S.E.2d 648) (1996); Plott v. Cloer, 219 Ga. App. 130, 131 (1) ( 464 S.E.2d 39) (1995). Neither does Doe argue on appeal that failing to provide security in the common areas was a proximate cause of the criminal attack within the leased premises.

Godwin [v. Olshan, 161 Ga. App. 35, 36 ( 288 S.E.2d 850) (1982)]; Maloof v. Blackmon, 105 Ga. App. 207, 208 ( 124 S.E.2d 441) (1962)." Gale v. North Meadow Assoc., 219 Ga. App. 801, 802 ( 466 S.E.2d 648) (1996). Here, as in Gale, there has been no showing made by plaintiffs to refute Clairmont's evidence that it had no duty to provide security inside any of the leased spaces.

Under O.C.G.A. § 5131, a landlord has a duty to exercise ordinary care to avoid injury to invitees and tenants, but this duty to "keep safe portions of the leased premises designated as common areas in which the landlord has reserved a qualified right of possession, does not extend to the leased areas of the premises over which the tenant has exclusive possession and control." Gale v. N. Meadow Assocs. Joint Venture, 219 Ga. App. 801, 80203 (1995). Here, there were no "common areas" on the premises.

Georgia courts have applied that general rule in other cases evaluating negligence claims under OCGA § 44-7-14. See, e.g., Gale v. N. Meadow Assoc. Joint Venture , 219 Ga. App. 801, 803, 466 S.E.2d 648 (1995) (affirming summary judgment for landlord under "the landlord’s limited liability under OCGA § 44-7-14," because there was no evidence of prior acts from which the landlord could have "reasonably foreseen the attack" by a co-worker) (citation and punctuation omitted) (physical precedent only); Jones , 198 Ga. App. at 85, 400 S.E.2d 364 (in case brought under OCGA § 44-7-14, affirming summary judgment for landlord for injuries caused when tenant fell in sinkhole on leased property because "[t]here was no evidence to show that the [landlords], any more than the [tenants], should reasonably have foreseen the creation of such a hole appearing by the continuing erosion of the stream embankment").Our Court of Appeals, moreover, has acknowledged the role of foreseeability where negligence is alleged in the dog-bite context, including under OCGA § 44-7-14.

See La Quinta Inns v. Leech, 289 Ga.App. 812, 817(1), 658 S.E.2d 637 (2008); Alexander, supra. See Alexander, supra;Gale v. North Meadow Assoc. Joint Venture, 219 Ga.App. 801, 803, 466 S.E.2d 648 (1995) (physical precedent only). 3. McCrary contends that the trial court erred in granting MGM's motion for summary judgment because material issues of fact exist as to whether Morris's death proximately resulted from MGM's negligence.