cogently observed, “[TJhere are clear judicial days on which a court can foresee forever and thus determine liability but none on which that foresight alone provides a socially and judicially acceptable limit on recovery of damages for that injury.” Thing v. La Chusa, 48 Cal. 3d 644, 668, 771 P.2d 814, 257 Cal. Rptr. 865 (1989). 9 A number of other jurisdictions have employed forms of the prior similar incidents approach, though some of them employ that approach to the exclusion of others. See, e.g., Baptist Mem’l Hosp. v. Gosa, 686 So. 2d 1147, 1152-53 (Ala. 1996); Ann M. v. Pac. Plaza Shopping Ctr., 6 Cal. 4th 666, 679, 863 P.2d 207, 25 Cal. Rptr. 2d 137 (1993), disapproved on another point in Reid v. Google, Inc., 50 Cal. 4th 512, 527 n.5, 235 P.3d 988, 113 Cal. Rptr. 3d 327 (2010) (<HOLDING>); Drayton v. Kroger Co., 297 Ga. App. 484, 485,
holding that in determining whether to impose a duty the following factors must be balanced 1 the relationship between the parties 2 the reasonable foreseeability of harm to the person injured and 3 public policy concerns holding no duty and noting that foreseeability bears on the scope of a duty and not whether it exists in the first place holding that a reference to the violent crime sentencing statute in the second degree assault statute required automatic imposition of violent crime sentencing for a defendant convicted of second degree assault holding that a high degree of foreseeability is required to impose a duty to hire security guards and that the requisite degree of foreseeability rarely if ever can be proven in the absence of prior similar incidents of violent crime on the landowners premises holding that an aggrieved party is not required to prove that his property would in fact suffer the requisite degree of harm before he can seek judicial assistance