In addition to finding the landlord of the victimized woman liable in tort, the Kline court also found an implied contractual agreement. In interpreting the Kline decision, some State courts have denied recovery to plaintiffs based on the contract aspect of Kline while accepting recovery based on the case's tort principles. Some States, such as Illinois, have refused to recognize any landlord liability. Progress has been made to ensure justice for tenants in New Jersey, California, and Michigan, where recent cases have greatly expanded the idea of tort liability for landlords whose negligence has created an environment conducive to criminal attacks. The plaintiff's attorney should examine case facts for the following circumstances, any one of which may be useful in convincing a judge to impose a duty to protect or to convince a jury to find a breach of that duty: (1) incidence of crime in the neighborhood, (2) prior incidents of criminal behavior in the building, (3) identity of attacker (if known), (4) personnel employed by the landlord, (5) pattern of rule enforcement with other tenants, (6) physical maintenance of the building, (7) security personnel employed, (8) local police procedure, (9) lease or occupancy agreement, (10) statutory standards, and (11) warning to tenant. Three notes are provided.