Lau's Corp., Inc. v. Haskins, 405 S.E.2d 474 (Ga. 1991). · Go Syfert
Lau's Corp., Inc. v. Haskins, 405 S.E.2d 474 (Ga. 1991). Cases Citing This Book View Copy Cite
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examined Cited "but see" WELCH v. PAPPAS RESTAURANTS, INC. (Two Cases) (30×) also: Cited as authority (rule), Cited "see", Cited "see, e.g."
Ga. · 2023 · signal: but see · confidence high
But see Lau’s Corp., 261 Ga. at 494 (3) (“A landowner does not become an insurer of safety by taking some security precautions on behalf of invitees.”).
examined Cited as authority (verbatim quote) Villages of Cascade Homeowners Association, Inc. v. Herbert Edwards (3×) also: Cited as authority (rule)
Ga. Ct. App. · 2022 · quote attribution · 1 verbatim quote · confidence high
if there is no evidence sufficient to create a genuine issue as to any essential element of plaintiff's claim, that claim tumbles like a house of cards. all of the other disputes of fact are rendered immaterial.
examined Cited as authority (verbatim quote) PATTERSON v. KEVON, LLC
Ga. · 2018 · signal: see · quote attribution · 1 verbatim quote · confidence high
if there is no evidence sufficient to create a genuine issue as to any essential element of plaintiff's claim, that claim tumbles like a house of cards. all of the other disputes of fact are rendered immaterial.
examined Cited as authority (quoted) AMAC TWO, LLC v. WEB, LTD. (2×) also: Cited "see"
Ga. Ct. App. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
if there is no evidence sufficient to create a genuine issue as to any essential element of plaintiff's claim, that claim tumbles like a house of cards. all of the other disputes of fact are rendered immaterial.
discussed Cited as authority (quoted) Whitfield v. Tequila Mexican Restaurant No. 1, Inc. (2×) also: Cited as authority (rule)
Ga. Ct. App. · 2013 · quote attribution · 1 verbatim quote · confidence low
if the proprietor has reason to anticipate a criminal act, he or she then has a 'duty to exercise ordinary care to guard against injury from dangerous characters.
discussed Cited as authority (quoted) Don Anthony Whitfield v. Tequila Mexican Restaurant No. 1 (2×) also: Cited as authority (rule)
Ga. Ct. App. · 2013 · quote attribution · 1 verbatim quote · confidence low
if the proprietor has reason to anticipate a criminal act, he or she then has a 'duty to exercise ordinary care to guard against injury from dangerous characters.
discussed Cited as authority (quoted) Johnson v. Comcar Industries, Inc.
Ga. Ct. App. · 2001 · quote attribution · 1 verbatim quote · confidence low
if there is no evidence sufficient to create a genuine issue as to any essential element of plaintiff's claim, that claim tumbles like a house of cards.
discussed Cited as authority (rule) Georgia Bone & Joint Surgeons, P.C. v. Keel
Ga. · 2026 · signal: cf. · confidence medium
Cf. Lau’s Corp v. Haskins, 261 Ga. 491, 493 (1991) (noting in premises-liability context that “[t]he particular standard of care to be applied and whether the owner breached that standard are usually issues to be decided by a jury”).
discussed Cited as authority (rule) Roland v. Wingate Management Company, LLC
N.D. Ga. · 2025 · confidence medium
“It is also generally accepted that, while a proprietor is ‘bound to exercise ordinary care to protect the invitee from unreasonable risks’ of which he has knowledge, he is not an insurer of an invitee’s safety.” Id. at 218–19 (quoting Lau’s Corp. v. Haskins, 405 S.E.2d 474, 476 (Ga. 1991)).
discussed Cited as authority (rule) Tia Matthews v. Gibson Holdings, LLC
Ga. Ct. App. · 2025 · confidence medium
“To prevail at summary judgment under OCGA § 9-11-56, the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) VINICIO A. DIAZ ARRIOLA v. KEITH COLEMAN
Ga. Ct. App. · 2025 · confidence medium
(Emphasis omitted.) Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) STERLING PLANET, INC. v. GRP HOLDCO, LLC
Ga. Ct. App. · 2025 · confidence medium
As a counterclaim defendant, GRP need not affirmatively disprove Sterling’s claim; “instead, the burden on the moving party may be discharged by pointing out by reference to the affidavits, depositions and other documents in the record that there is an absence of evidence to support the nonmoving party’s case.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) KADEDRA GLOVER v. COREY DEAN MOORE
Ga. Ct. App. · 2025 · confidence medium
“To prevail at summary judgment, under OCGA § 9-11-56, the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) SUNTRUST BANK v. CHARLES DANIEL BICKERSTAFF
Ga. Ct. App. · 2025 · confidence medium
“On appeal from the grant or denial of summary judgment, we apply a de novo standard of review.” Ga. Cash America, Inc. v. Greene, 318 Ga. App. 355, 358 (2) ( 734 SE2d 67 ) (2012) (citation and punctuation omitted). “[T]he moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 (405 SE2d. 474) (1991).
discussed Cited as authority (rule) MERCY HOUSING GEORGIA, III L.P. v. MICHAEL JOHN KAAPA
Ga. Ct. App. · 2023 · confidence medium
“To prevail at summary judgment under OCGA § 9-11-56, the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) Angela Tucker v. City of Thomasville
Ga. Ct. App. · 2023 · confidence medium
OCGA § 9-11-56 (c).” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) Armer Early v. Morgan Fleet Services, Inc.
Ga. Ct. App. · 2023 · confidence medium
OCGA § 9-11-56 (c).” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) CHILDREN'S WORLD LEARNING CENTER v. BRANDICE CARTER
Ga. Ct. App. · 2022 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) BROWN v. FEDEX FREIGHT INC
M.D. Ga. · 2022 · confidence medium
Cowart, 287 Ga. at 623; citing Lau’s Corp. v. Haskins, 261 Ga. 491, 491 (1991) abrogated on other grounds.
cited Cited as authority (rule) Anthony Gilchrist v. Meldi Sub, LLC
Ga. Ct. App. · 2022 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991). 2 ran along the storefront of the gas station’s convenience store and an adjoining Subway shop.
discussed Cited as authority (rule) TERESSA BLONDELL v. COURTNEY STATION 300 LLC (2×) also: Cited "see"
Ga. Ct. App. · 2021 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991) (emphasis omitted).
discussed Cited as authority (rule) TERESSA BLONDELL v. COURTNEY STATION 300 LLC (2×) also: Cited "see"
Ga. Ct. App. · 2021 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991) (emphasis omitted).
discussed Cited as authority (rule) TAIRAN BLAKE v. TRIBE EXPRESS, INC.
Ga. Ct. App. · 2021 · confidence medium
Because only reasonable inferences can give rise to a genuine issue of material fact sufficient to preclude summary judgment, see Lau’s Corp. v. Haskins, 261 Ga. 491, 495 (4) ( 405 SE2d 474 ) (1991), the trial court did not err by passing on the reasonableness of the inference that Prosser was lost, which was premised on circumstantial evidence, in light of the direct evidence that Prosser was not acting in the course and scope of his employment.
discussed Cited as authority (rule) University Health Services, Inc v. Christopher Shawn Clancy
Ga. Ct. App. · 2021 · confidence medium
Thus, construed in the light most favorable to the appellees, we cannot find, as a matter of law “that there is no evidence sufficient to create a jury issue on at least one essential element of [the appellees’] case.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) Sheri Mimbs v. Henry County Schools
Ga. Ct. App. · 2021 · confidence medium
(Emphasis omitted.) Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) James Zulke v. Ac & Dc Power Technologies, LLC
Ga. Ct. App. · 2020 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) Daniel Gryder v. Trey Conley
Ga. Ct. App. · 2019 · confidence medium
OCGA § 9-11-56 (c).” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
examined Cited as authority (rule) George Hill v. Mm Gas & Food Mart, Inc. (3×) also: Cited "see, e.g."
Ga. Ct. App. · 2019 · confidence medium
Lau’s Corp., Inc., 261 Ga. at 494 (2) (plaintiff must come forward with facts enabling a jury to find that the owner “failed to take reasonable steps to protect them against injury.” (citation omitted; emphasis supplied)).
cited Cited as authority (rule) Keisha Shane Odum v. Cynthia L. Harn
Ga. Ct. App. · 2019 · confidence medium
(Emphasis omitted.) Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) Charles B. Brown v. Janice Dickerson
Ga. Ct. App. · 2019 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) PATTERSON Et Al. v. KEVON, LLC (2×)
Ga. Ct. App. · 2017 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) PHILLIPS Et Al. v. OWNERS INSURANCE COMPANY
Ga. Ct. App. · 2017 · confidence medium
Because this case arises from a decision on Owners’ summary judgment motion, we view the facts in a light most favorable to Phillips as the nonmoving party Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) Hardin v. Hardin
Ga. · 2017 · confidence medium
OCGA § 9-11-56 (c).” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) Hardin v. Hardin
Ga. · 2017 · confidence medium
OCGA § 9-11-56 (c).” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
examined Cited as authority (rule) Martin v. Six Flags Over Georgia II, L.P. (4×) also: Cited "see", Cited "see, e.g."
Ga. · 2017 · confidence medium
OCGA § 51-3-1. 3 With regard to potential criminal attacks by third parties, the landowner is “not the insurer of the invitee’s safety,” but nonetheless is required “to exercise ordinary care to protect the invitee from unreasonable risks of which he or she has superior knowledge.” Lau 's Corp. v. Haskins, 261 Ga. 491, 492 (1) ( 405 SE2d 474 ) (1991).
examined Cited as authority (rule) SIX FLAGS OVER GEORGIA II, L.P. v. MARTIN (4×) also: Cited "see", Cited "see, e.g."
Ga. · 2017 · confidence medium
That is not to say that a patron cannot 9 With regard to potential criminal attacks by third parties, the landowner is “not the insurer of the invitee’s safety,” but nonetheless is required “to exercise ordinary care to protect the invitee from unreasonable risks of which he or she has superior knowledge.” Lau’s Corp. v. Haskins, 261 Ga. 491, 492 (1) ( 405 SE2d 474 ) (1991).
examined Cited as authority (rule) Fair v. CV Underground, LLC (3×)
Ga. Ct. App. · 2017 · confidence medium
Robinson v. Kroger Co., 268 Ga. 735, 740 (1) ( 493 SE2d 403 ) (1997); Lau’s Corp. v. Haskins, 261 Ga. 491, 492 (1) ( 405 SE2d 474 ) (1991).
examined Cited as authority (rule) Michael C. Fair v. Cv Underground, LLC (3×)
Ga. Ct. App. · 2017 · confidence medium
Robinson v. Kroger Co., 268 Ga. 735, 740 (1) ( 493 SE2d 403 ) (1997); Lau’s Corp. v. Haskins, 261 Ga. 491, 492 (1) ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) Youngblood v. All American Quality Foods, Inc. (2×)
Ga. Ct. App. · 2016 · confidence medium
Parks v. Multimedia Technologies, 239 Ga. App. 282, 286-287 (2) ( 520 SE2d 517 ) (1999) (citations, punctuation and emphasis omitted); Lau’s Corp. v. Haskins, 261 Ga. 491, 495 (4) ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) Adewumi v. Amelia grove/ashland Park Homeowners Association, Inc.
Ga. Ct. App. · 2016 · confidence medium
Where a defendant moving for summary judgment demonstrates the absence of a genuine issue of material fact and that the undisputed evidence warrants judgment as a matter of law, “the nonmoving party cannot rest on its pleadings, but rather must point to specific evidence giving rise to a triable issue.” Lau’s Corp., Inc. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991); OCGA § 9-11-56 (e).
discussed Cited as authority (rule) The Eichholz Law Firm, Pc v. Tate Law Group, LLC. Et At. (2×)
Ga. Ct. App. · 2016 · confidence medium
Cowart v. Widener, 287 Ga. 622, 623 (1) ( 697 SE2d 779 ) (2010), citing Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991) and OCGA § 9-11-56 (e).
discussed Cited as authority (rule) STANDARD v. FALSTAD Et Al.
Ga. Ct. App. · 2015 · confidence medium
OCGA § 9-11-56; Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991) (defendant entitled to summary judgment by showing no evidence sufficient to create a jury issue on at least one essential element of plaintiff’s case).
cited Cited as authority (rule) GRAVITT Et Al. v. OLENS
Ga. Ct. App. · 2015 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
cited Cited as authority (rule) McDonald v. West Point Food Mart, Inc.
Ga. Ct. App. · 2015 · confidence medium
Lau’s Corp. v. Haskins, 261 Ga. 491, 493 ( 405 SE2d 474 ) (1991) (citations and punctuation omitted).
discussed Cited as authority (rule) The Medical Center Hospital Authority v. Marion Baker (2×)
Ga. Ct. App. · 2015 · confidence medium
See also Days Inn of America v. Matt, 265 Ga. 235, 236 ( 454 SE2d 507 ) (1995); Lau’s Corp. v. Haskins, 261 Ga. 491, 492 (1) ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) Kennestone Hospital, Inc. v. the Travelers Home and Marine Insurance Company
Ga. Ct. App. · 2015 · confidence medium
However, as TH&M points out, once it demonstrated that Kennestone failed to send notice to the insured, it was incumbent upon Kennestone to show that this failure should not invalidate its lien, and if the reason it did not send the insured notice was because it was unaware of her identity, it should have put forth some competent evidence to support that assertion. 6 E.g., Cowart v. Widener, 287 Ga. 622, 623 (1) ( 697 SE2d 779 ) (2010); Lau’s Corp., Inc. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
discussed Cited as authority (rule) Wpd Center, LLC v. Watershed, Inc.
Ga. Ct. App. · 2014 · confidence medium
To prevail on a motion for summary judgment, “the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991); OCGA § 9-11-56.
discussed Cited as authority (rule) RUMSEY v. GILLIS Et Al.
Ga. Ct. App. · 2014 · confidence medium
To prevail on a motion for summary judgment, “the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991); OCGA § 9-11-56.
discussed Cited as authority (rule) Cope v. Evans
Ga. Ct. App. · 2014 · confidence medium
To prevail on a motion for summary judgment, “the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991); OCGA § 9-11-56.
cited Cited as authority (rule) Randy Taylor v. Kimberly Ann McGraw
Ga. Ct. App. · 2014 · confidence medium
OCGA § 9–11–56 (c).” Lau’s Corp. v. Haskins, 261 Ga. 491, 491 ( 405 SE2d 474 ) (1991).
LAU’S CORPORATION, INC.
v.
HASKINS Et Al.
S91G0720.
Supreme Court of Georgia.
Jun 27, 1991.
405 S.E.2d 474
Bentley, Karesh, Seacrest, Labovitz & Campbell, Edwin A. Tate II, Jeanne F. Johnson, for appellant., Dozier, Akin & Lee, Lester Z. Dozier, Jr., for appellees.
Clarke, Weltner, Divisions.
Cited by 2,022 opinions  |  Published
3 passages pin-cited by 6 cases
Pinpoint authority: #17,185 of 633,719
Citer courts: Court of Appeals of Georgia (5) · Supreme Court of Georgia (1)
Clarke, Chief Justice.

Sarah and Louis Haskins were robbed by two men in the parking lot adjoining the China King Restaurant. Louis Haskins was hit in the head and Sarah Haskins’ purse was snatched. The Haskinses brought an action against the China King Restaurant alleging that it failed to provide adequate warning or security for its patrons. The trial court granted summary judgment to the restaurant. The Court of Appeals reversed. Haskins v. Lau’s Corp., 198 Ga. App. 470 (402 SE2d 58) (1991). We granted certiorari and reverse the Court of Appeals.

To prevail at summary judgment under OCGA § 9-11-56, the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law. OCGA § 9-11-56 (c). A defendant may do this by showing the court that the documents, affidavits, depositions and other evidence in the record reveal that there is no evidence sufficient to create a jury issue on at least one essential element of plaintiff’s case. If there is no evidence sufficient to create a genuine issue as to any essential element of plaintiff’s claim, that claim tumbles like a house of cards. All of the other disputes of fact are rendered immaterial. See, e.g., Holiday Inns v. Newton, 157 Ga. App. 436 (278 SE2d 85) (1981). A defendant who will not bear the burden of proof at trial need not affirmatively disprove the nonmoving party’s case; instead, the burden on the moving party may be discharged by pointing out by reference to the affidavits, depositions and other documents in the record that there is an absence of evidence to support the nonmoving party’s case. If the moving party discharges this burden, the nonmoving party cannot rest on its pleadings, but rather must point to specific evidence giving rise to a triable issue. OCGA § 9-11-56 (e).

In their complaint Sarah and Louis Haskins alleged that they were attacked and seriously injured on December 23, 1987, in the parking lot of the China King Restaurant. They alleged that the proprietor, Sun-Lung Van, knew that his patrons were in danger of criminal attack, but failed to provide adequate warning or provide adequate security. The restaurant filed a motion for summary judgment, citing the affidavit of Mr. Van, who stated that he had operated the business since 1984 and was aware of only one other criminal incident that had occurred at or near his restaurant. On December 19, 1987, a woman’s purse was snatched in the parking lot. The woman was not physically injured. He also stated that the China King Restaurant operated four floodlights at the front of the restaurant that were directed at the parking lot and two floodlights on his business sign, located in the parking lot. The lot was also indirectly lit by streetlights[*492] and the lights from adjoining businesses. Further, after the December 19 purse snatching, he patrolled his parking lot several times each evening.

In response to the motion for summary judgment, the Haskinses filed the affidavits of two police officers who described the December 19 purse snatching, and the affidavits of two local business people who stated that the neighborhood where the China King Restaurant is located is, in their opinion, a high crime area. They stated that they have heard that businesses in the area have experienced problems with robberies or burglaries. They did not describe, however, any precautions that they or other businesses in the area have taken to protect their patrons against the risk of criminal attack. The depositions of Mr. and Mrs. Haskins are also in the record.

The traditional elements of a negligence case are:

(1) A duty, or obligation, recognized by law, requiring the actor to conform to a certain standard of conduct, for the protection of others against unreasonable risks.
(2) A failure on his part to conform to the standard required
(3) A reasonable close causal connection between the conduct and the resulting injury . . .
(4) Actual loss or damage resulting to the interests of the other.

Sutter v. Hutchings, 254 Ga. 194, 196-197 (327 SE2d 716) (1985) (quoting Prosser, Law of Torts, 4th ed., § 30 (1971)). In the motion for summary judgment in this case, defendant asserts that there is an absence of evidence to support the first three elements of plaintiffs’ claim.

1. A proprietor’s duty to invitees is to “exercise ordinary care in keeping the premises and approaches safe.” OCGA § 51-3-1. The proprietor is not the insurer of the invitee’s safety, Pound v. Augusta Nat., 158 Ga. App. 166 (279 SE2d 342) (1981), but is bound to exercise ordinary care to protect the invitee from unreasonable risks of which he or she has superior knowledge. Atlanta Gas Light Co. v. Gresham, 260 Ga. 391 (394 SE2d 345) (1990). If the proprietor has reason to anticipate a criminal act, he or she then has a “duty to exercise ordinary care to guard against injury from dangerous characters.” Atlantic C. L. R. Co. v. Godard, 211 Ga. 373, 377 (86 SE2d 311) (1955).

In this case, the undisputed facts show that the Haskinses were invitees on the restaurant property. It is also undisputed that Mr. Van, the proprietor, knew about one previous purse snatching in his parking lot. Further, giving the plaintiffs the benefit of all reasonable[*493] inferences from the affidavits in the record, it is also possible that Mr. Van knew that his business is located in a “high crime” area. We therefore conclude that, although plaintiffs’ evidence as to the “duty” element of the tort claim is weak, it is sufficient to give rise to a triable issue as to whether Mr. Van had a duty to exercise ordinary care to guard his patrons against the risk posed by criminal activity.

2. Exactly what constitutes “ordinary care” varies with the circumstances and the magnitude of the danger to be guarded against. Prosser, Law of Torts, 4th ed., §§ 31 and 33 (1971). “Since it is impossible to prescribe definite rules in advance for every combination of circumstances which may arise, the details of the standard must be filled in each particular case.” Id. at § 37, p. 207. Lowe v. Atlanta Masonic Temple Co., 79 Ga. App. 575 (54 SE2d 677) (1949). But, to be negligent, the conduct must be unreasonable in light of the recognizable risk of harm. Pound, supra at 168. See also Prosser, Law of Torts 4th ed., § 31, p. 147.

The particular standard of care to be applied and whether the owner breached that standard are usually issues to be decided by a jury. Pound, supra. However, these issues may be decided by the court in plain and palpable cases where “reasonable minds cannot differ as to the conclusion to be reached.” Id. at 167. In this case, the Haskinses assert that Mr. Van breached his duty of ordinary care by failing to warn them that they were in a dangerous neighborhood and by “failing to provide adequate security for the protection of the plaintiff or other patrons.” We conclude, however, that, even giving the Haskinses the benefit of every reasonable inference from the evidence in the record, a reasonable jury could not find that Mr. Van had breached his duty of care.

We address first the failure to warn. Many circumstances may require a landowner to warn the invitee of latent dangers. See, e.g., Knowles v. La Rue, 102 Ga. App. 350 (116 SE2d 248) (1960); Ward v. Veterans of Foreign Wars Post 2588, 109 Ga. App. 563 (136 SE2d 481) (1964); Sutton v. Sutton, 145 Ga. App. 22 (243 SE2d 310) (1978). Certainly, a high crime rate in a particular area may increase the risk of harm to patrons so that a prudent owner will take security precautions. We decline, however, to require owners to post signs warning of a generalized risk of crime. It is difficult even to imagine what such warnings would include: “Watch out! This is a high crime neighborhood,” or, “Since 1982, two rapes and one robbery have occurred in this parking lot.” Plaintiffs cite no authority — and we find none — requiring landowners to warn invitees of a generalized risk of crime. We conclude that no such duty currently exists in the law.

Next, we address the Haskinses’ contention that the restaurant failed to provide “adequate security.” To avoid entry of summary judgment in a premises liability case, plaintiffs may not simply point[*494] to their injuries as evidence that the landowner failed to take reasonable precautions to protect them. Jones v. Interstate North Assoc., 145 Ga. App. 366 (243 SE2d 737) (1978). Instead, plaintiffs must come forward with facts from which a reasonable jury could conclude that the owner or occupier failed to take reasonable steps to protect them against injury. OCGA § 9-11-56 (e).

The only evidence in this case regarding the level of security at the parking lot was submitted by the proprietor and shows that the lot was well lit, [1] was located immediately adjoining a busy restaurant on a street that was lit by streetlights and populated with other occupied businesses. Further, the proprietor himself checked his parking lot periodically to make sure no one was lingering there. In response to this evidence, the Haskinses have not presented any evidence that the condition of the parking lot fell below reasonable security standards, e.g., that the lights were not working, or that deep shadows provided places for criminals to lurk, or that other local proprietors had found it necessary to hire security guards, etc. In sum, there is no evidence that the proprietor’s conduct failed to conform to the standard of care required.

3. Having concluded that there is no evidence of breach of the duty of care, it would ordinarily be unnecessary to address any other issues. For clarity of analysis, however, we will review the other divisions of the Court of Appeals opinion. In Division 2, the Court of Appeals held that because Mr. Van had undertaken to patrol the parking lot, a genuine issue of fact remained as to whether he had done so non-negligently.

[Mr. Van] failed to demonstrate that, as a matter of law, ordinary care in the exercise of the duty [he] had assumed to provide parking lot security did not require additional security measures, such as increased lighting, issuing warnings to [the] patrons, instituting a constant nighttime patrol, or offering to escort patrons to their cars. Haskins v. Lau’s Corp., supra at 471.

The implication of this statement is that Mr. Van somehow raised the standard of care that applies to him by making the effort to patrol his parking lot. We cannot agree. A landowner does not become an insurer of safety by taking some security precautions on behalf of invitees. Undertaking measures to protect patrons does not heighten the standard of care; and taking some measures does not ordinarily con[*495] stitute evidence that further measures might be required. [2] In all cases, a landowner is not required to do more than is reasonable for the protection of invitees. Prosser, supra at § 56.

Decided June 27, 1991 — Reconsideration denied July 24, 1991. Bentley, Karesh, Seacrest, Labovitz & Campbell, Edwin A. Tate II, Jeanne F. Johnson, for appellant. Dozier, Akin & Lee, Lester Z. Dozier, Jr., for appellees.

4. Finally, the Court of Appeals held in Division 3 of its opinion that as the movant for summary judgment, the restaurant had not met its burden to establish as a matter of law that its alleged negligence was not the proximate cause of the Haskinses’ injuries. As we noted above, at summary judgment a party who will not bear the burden of proof at trial need not conclusively prove the opposite of each element of the non-moving party’s case. Rather, that party must demonstrate by reference to evidence in the record that there is an absence of evidence to support at least one essential element of the non-moving party’s case. In other words, summary judgment is appropriate when the court, viewing all the facts and reasonable inferences from those facts in a light most favorable to the non-moving party, concludes that the evidence does not create a triable issue as to each essential element of the case. In so holding, we overrule anything to the contrary. See, e.g., Ryder Truck Rental v. Carter, 189 Ga. App. 43 (374 SE2d 830) (1988); Corbitt v. Harris, 182 Ga. App. 81 (354 SE2d 637) (1987); Fort v. Boone, 166 Ga. App. 290 (304 SE2d 465) (1983).

In sum, we conclude that there is no evidence of negligence in this case and that defendant was entitled to summary judgment as a matter of law.

Judgment reversed.

All the Justices concur, except Weltner, J., who dissents as to Divisions 2 through 4 and the judgment line.
1

The Haskinses attempt to rely on a statement in Mr. Haskins’ deposition where he stated that, “It was definitely dark.” It is clear from the context of this remark, however, that he was referring to whether it was day or night at the time of the robbery.

2

If a defendant undertakes to do more for the benefit of another person than the law requires, he or she may be held liable if he or she acts unreasonably or makes the situation worse, by increasing the danger, or by misleading the plaintiff into belief that it has been removed, or by depriving the plaintiff of the possibility of help from other sources, etc. Prosser, supra at § 56, p. 347.