What is the standard to recover damages from a property owner for injuries caused by a criminal's acts?

The owner must have known, or should have known, of the probability of a third party's conduct which was likely to endanger the safety of persons lawfully on the premises, according to the Second Department, in Rodriguez v. 1705 & 1715 Caton Associates, decided on April 10, 2007. The court noted that plaintiff's conclusory allegations as to prior robberies were insufficient to raise a triable issue of fact.