The association is generally not liable for criminal acts unless, because of prior incidents or other factors, it is reasonably foreseeable that similar future criminal acts might occur. In that case, the association must take reasonable steps to help prevent those future acts. Some cases have held, however, that an association’s duty to the residents is similar to that of a landlord, who owes a duty of reasonable care to protects its residents from the foreseeable risk of criminal activity (Frances T. v. Village Green Owners Association (1986) 42 Cal.3d 490, 229 Cal.Rptr. 456).