Georgia decisions considering the liability of property owners for criminal acts by third parties uniformly limit their discussions to the claims of invitees. See, e.g., Rice v. Six Flags Over Ga., LLC, 257 Ga. App. 864, 866-867 ( 572 S.E.2d 322) (2002), and cases cited therein. In contrast, under OCGA § 51-3-2(b), a landowner is "liable to a licensee only for willful or wanton injury.

In arguing that this incident was not foreseeable, Chevron cites Georgia premises liability cases providing that property owners have a duty to exercise ordinary care to protect invitees from foreseeable third-party criminal attacks where there are prior similar criminal acts occurring on the premises that put the property owner on notice of the dangerous condition. See Rice v. Six Flags Over Ga., LLC, 257 Ga.App. 864, 572 S.E.2d 322, 325-26 (2002); Johnson v. Atl. Hous. Auth., 243 Ga.App. 157, 532 S.E.2d 701, 703 (2000). Chevron argues that the criminal attack by Muhammad on Antoine was not foreseeable because this particular Chevron station was in a low crime area and had not been the site of any criminal activity in previous years, much less violent crime.

Defendant has pointed to only one premises liability case based on third-party criminal conduct (as opposed to slip-and-fall physical hazards) where the crime victim’s "superior knowledge" of the risk of violence was at issue. In Rice V. Six Flags Over Georgia, LLC, 257 Ga. App. 864, 867-868, 572 S.E.2d 322 (2002), we affirmed the grant of summary judgment to the landowner because the sexual molestation of the victim in that case was not foreseeable to the landowner for a lack of substantially similar prior crimes. We also held that, even if the criminal act was foreseeable to the landowner, the victim’s knowledge of the danger she faced from the park guest who assaulted her was equal or superior to the landowner’s — hence, she could not recover because she "fail[ed] to exercise reasonable care to avoid the danger."

In arguing that D. L.'s alleged rape was not foreseeable, St. Francis cites Rice v. Six Flags Over Ga., 257 Ga.App. 864 (572 S.E.2d 322) (2002). In Rice, the family of a 14-year-old girl brought a premises liability action against the amusement park, alleging that the girl was assaulted by a fellow passenger on a "roller coaster thrill ride featuring multiple inversions while in a locked-down restraint system."

(Citation and punctuation omitted.) Rice v. Six Flags Over Ga., LLC, 257 Ga. App. 864 , 868 (572 SE2d 322 ) (2002). Causation is an essential element of nuisance, trespass, and negligence claims.

Id. (plaintiffs employer did not have superior knowledge of danger to plaintiff from her homicidal husband). See also Rice v. Six Flags Over Go., 257 Ga. App. 864, 868 ( 572 SE2d 322) (2002) (amusement park proprietor not liable for criminal attack on plaintiff on park ride; plaintiff had superior knowledge of risk where, even though she was fearful, she did not notify park authorities). see Reid v. Augusta-Richmond County Coliseum Auth., 203 Ga. App. 235, 239 (2) ( 416 SE2d 776) (1992) (proprietor not liable for injuries to plaintiff resulting from attack by one with "pre-existing personal animosity" to plaintiff) (id. at 237 (1)).

(Citation and punctuation omitted.) Rice v. Six Flags Over Ga., 257 Ga. App. 864, 865 ( 572 SE2d 322) (2003). So viewed, the evidence shows that McCollum went to the Kmart pharmacy to have a prescription filled.

(Punctuation omitted.) Rice v. Six Flags Over Ga., 257 Ga. App. 864, 867 ( 572 SE2d 322) (2002).Spear v. Calhoun, 261 Ga. App. 835, 836 (1) ( 584 SE2d 71) (2003).

Therefore, Dolphin Realty was entitled to summary judgment on this basis. E.g., Rice v. Six Flags c., 257 Ga. App. 864, 868 ( 572 SE2d 322) (2002); Johnson v. Atlanta Housing Auth., supra. Additionally, there was sufficient evidence that the claimed inadequacy of the lighting was the cause in fact of the assailant's ability to gain access to her apartment. For instance, there is no indication that the assailant was not a resident of the complex with equal access to all common areas, regardless of lighting.

Watson argues that the companies had a duty to anticipate harm and protect her because her assault was foreseeable based on "prior reports of criminal violence . . . on the premises," but the records introduced by Watson are devoid of any details about the location, nature, or extent of the prior incidents to prove that they were similar to Watson's assault, Raines v. Maughan, 312 Ga. App. 303, 305, 718 S.E.2d 135, 138 (2011). And even if we were to assume that the companies had a duty to protect Watson, the companies were not liable unless they failed to exercise ordinary care to protect her, see Rice v. Six Flags Over Ga., LLC, 257 Ga. App. 864, 868, 572 S.E.2d 322, 326 (2002), and could have prevented the assault by employing different security measures, see Knudson v. Lenny's, Inc., 202 Ga. App. 85, 86, 413 S.E.2d 258, 260 (1991). Watson argues that her testimony that she did not see any police officers at the fair "prove[s] that security was not sufficient," but Watson acknowledged that a police officer approached her shortly after the assault and that he escorted her to an ambulance for treatment.