array of evidence may be relevant to establishing the scope of a duty owed. In Miller, we allowed “[e]vidence of conduct of patrons on prior occasions ... to show similar conduct could reasonably have been anticipated.” 58 Wn.2d at 884-85. In Niece, we explained the question of foreseeability 10, 914 (2011) (rejecting prior criminal incidents as the sine qua non of determining foreseeability). Moreover, it would suggest, absurdly, that a business owner who relocates after an incident occurs no longer owes a duty to use reasonable care, insofar as he has no past experience of prior acts on the new premises. Even states that embrace a modified similar acts test have not gone so far. See Ann M. v. Pac. Plaza Shopping Ctr., 6 Cal. 4th 666, 679 n.7, 863 P.2d 207, 25 Cal. Rptr. 2d 137 (1993) (<HOLDING>), disapproved on another point in Reid v.
recognizing that of course in a given situation offenses may be of the same or similar character and at the same time constitute a series of connected acts or parts of a single scheme recognizing that while a duty to supply security guards may require evidence of prior similar acts under californias sliding scale foreseeability inquiry such act need not be on the same premises holding that sexual assault was not foreseeable because plaintiff produced no evidence of similar criminal acts on or near defendants premises holding foreseeability is based on the totality of the circumstances not on a mechanical prior similar incidents rule recognizing that californias homestead exemption is similar to ars  331101