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Bonanno v CCCTA -- California Supreme Court

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We elaborated on these principles in two cases involving criminal assaults committed on public property. In Peterson v. San Francisco Community College Dist. (1984) 36 Cal.3d 799 (Peterson), we held that the plaintiff, assaulted while using a public parking lot, properly alleged a dangerous condition of public property by her claim that thick and untrimmed trees and foliage around the lot "permitted the assailant to perpetrate his crime" (id. at p. 812). We explained that while third party conduct by itself, "unrelated to the condition of the property" (id. at p. 810), does not come within section 835, the public entity may, under some circumstances, be liable under that statute if it maintains its property in a manner that fails "to protect against harmful criminal conduct on its property." (Peterson, supra, at p. 811.)

More recently, in Zelig v. Co