Tort practitioners, which I am in part, still look at duty, breach, causation, 
and injury.? When looking at the "duty" there still is a distinction between 
acting and failing to act, with acting more likely to generate a duty.? For 
example, here in Washington State the courts ruled that there was no duty to 
rescue a boy badly injured in a car accident, lying more-or-less face down in a 
shallow puddle at the bottom of the road embankment.? A dozen or more hours 
after the alleged tortfeasors first saw him he died, apparently no longer able 
to lift his head out of the water to breathe.? Similarly, the basic rule is 
that apartment owners have no duty to act to protect tenants against criminal 
acts of other tenants, although an owner who is on notice that one tenant has 
invaded the unit of another, apparently through a common attic under the 
landlord's control, may be liable for subsequent criminal acts (which imposes a 
duty to act, the breach of which may establish liability).

And it is still an open question whether the landlord creates liability for 
himself by enacting either a no-guns or a guns-allowed policy.

Of course, the legislature can always establish?a duty to act, or not fail to 
act,?through legislation.

Eric Stahlfeld
Seattle, WA
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