Depending on the jurisdiction, the legal stipulations for what constitutes a negligent failure to predict the victimization of the plaintiff varies. Courts recognized in the latter half of the twentieth century that reasonable protection from “foreseeable crime” was only one kind of harm from which there was a duty to exist to protect against and to warn about. The concept is based on the right to control property. Those who control property owe a duty of care to those on the property who have little to no control. Such a duty is imposed by most jurisdictions, though its breadth and scope varies from state.