anticipate careless or criminal conduct on the part of third persons, either generally or at some particular time, he may be under a duty to take precautions against it, and to provide a reasonably sufficient number of servants to afford a reasonable protection. Restatement § 344 cmt. f. Thus, while the existence of a special relationship triggers a legal duty to protect, the Restatement recognizes limits on the scope of that duty. Liability cannot be imposed unless the landowner is on notice of likely harm. ¶46 Even when the business owner owes a duty under the circumstances, comment d explains that this does not make the business owner the insurer of an invitee’s safety but merely requires the exercise of reasonable care: A ... possessor of land who holds it open to P. 472 (1928) (<HOLDING>). ¶48 In Nivens, we recognized that because an
holding that a store owner has a duty to protect invitees from foreseeable criminal acts holding a business owner must protect invitees against injury caused by third persons holding landowner had duty to provide security in parking lot to protect its invitees from criminal acts of third parties holding that a residential landlord has no duty to protect invitees from foreseeable criminal acts holding a business owes a duty to protect invitees from reasonably foreseeable harm by third persons