The plaintiff in this case, a trespasser on the defendant’s land, asks us to abolish the common law rule limiting the liability of a landowner for injuries to trespassers and replace it with a negligence standard. We decline to do so and therefore affirm the district court’s grant of summary judgment to the defendant landowner.
I.Background Facts and Proceedings.
The defendant/appellee, Medical Associates Clinic, P.C., owns land upon which its office building is located. The defendant’s property includes an undeveloped, open field that abuts a residential area. Unknown to the defendant, the plaintiff/appellant, Monty Alexander, entered the field late one evening to retrieve his sister’s dog. Walking in darkness, he fell in a ditch and injured his knee.
The plaintiff filed this suit to recover damages for his injury, asserting the defendant was negligent in its maintenance of the property. After discovery, the defendant filed a motion for summary judgment alleging the undisputed facts established that the plaintiff was a trespasser and there were no facts to support a finding that the defendant breached its limited duty of care to a trespasser. The plaintiff resisted. The district court granted summary judgment, ruling (I) as a matter of law, the plaintiff was a trespasser, (2) the applicable standard of care was the avoid7 anee of willful and wanton injury, not negligence, and (3) there were no facts showing the defendant breached this duty of care. This appeal followed.
II. Scope of Review.
The scope of review for summary judgment rulings is familiar:
Our review of a summary judgment ruling is for the correction of errors of law. Summary judgment is appropriate where the moving party shows there are no genuine issues of material fact and it is entitled to judgment as a matter of law. In determining whether the moving party has met this burden, we view the record in the light most favorable to the party opposing the motion for summary judgment. This court’s role on appeal is “to determine whether a genuine issue of material fact exists and whether the law was correctly applied.”
Kelly v. Iowa Mut. Ins. Co., 620 N.W.2d 637, 641 (Iowa 2000) (citations omitted) (quoting Red Giant Oil Co. v. Lawlor, 528 N.W.2d 524, 528 (Iowa 1995)).
III. Issues on Appeal.
The issues raised on appeal are rather narrow. The plaintiff challenges- only the second part of the district court’s decision, namely, that the defendant must be judged by the common law duty to avoid willful and wanton injury to a trespasser. The plaintiff argues on appeal that the defendant should be held to a duty of reasonable care and that there is a factual issue as to whether that duty of care was breached. The plaintiff does not contest the district court’s ruling that, as a matter of law, he was a trespasser and that the defendant did not breach its common law duty of care to the plaintiff. Thus, the determinative issue on appeal is whether Iowa should abandon its common law rule of trespasser liability and replace it with a duty of reasonable care under the circumstances.
IV. Discussion.
Iowa has long adhered to the common law rule that “a possessor of land *76owes no duty to a trespasser other than not to injure him willfully or wantonly, and to use reasonable care after his presence becomes known to avoid injuring him.” Champlin v. Walker, 249 N.W.2d 839, 842 (Iowa 1977); accord Mann v. Des Moines Ry., 232 Iowa 1049, 1057, 7 N.W.2d 45, 51 (1942); Gwynn v. Duffield, 66 Iowa 708, 713, 24 N.W. 523, 525 (1885). Thus, a landowner’s duty with respect to a trespasser is twofold: (1) the landowner may not use his land in such a way that he deliberately or maliciously causes injury to a trespasser, and (2) once the landowner is aware of the presence of a trespasser, the landowner must use reasonable care to avoid injuring the trespasser. See generally Webster’s Third New International Dictionary 2575 (defining “wanton”), 2617 (defining “willful”). A “trespasser” is one who has no legal right to be upon another’s land and enters the land without the express or implied consent of the owner. Reasoner v. Chicago, Rock Island & Pac. R.R., 251 Iowa 506, 510, 101 N.W.2d 739, 741 (1960); Mann, 232 Iowa at 1056, 7 N.W.2d at 50.
The trespasser rule arose “out of the special privileges accorded the occupation of land” in feudal England. Rosenau v. City of Estherville, 199 N.W.2d 125, 135 (Iowa 1972); accord Kermarec v. Compagnie Generale Transatlantique, 358 U.S. 625, 630, 79 S.Ct. 406, 410, 3 L.Ed.2d 550, 554 (1959); 62 Am.Jur.2d Premises Liability § 79, at 431-32 (1990). The rule has continued to exist based on a belief that a property owner should not be obligated to make his or her property safe “or to keep it in any particular condition” for the benefit of intruders. Mann, 232 Iowa at 1062, 7 N.W.2d at 53. A well-known treatise on torts perhaps best articulates the rationale behind our trespasser rules:
The possessor of land has a legally protected interest in the exclusiveness of his possession. In general, no one has any right to enter without his consent, and he is free to fix the terms on which that consent will be given. Intruders who come without his permission have no right to demand that he provide them with a safe place to trespass, or that he protect them in their wrongful use of his property.
W. Page Keeton et al., Prosser and Keeton on the Law of Torts § 58, at 393 (5th ed.1984) [hereinafter Prosser on Torts],
The plaintiff points out that several jurisdictions have abolished the traditional analysis that determines the duty owed by a landowner based on the status of the injured party — invitee, licensee or trespasser. See Sheets v. Ritt, Ritt & Ritt, Inc., 581 N.W.2d 602, 604-05 (Iowa 1998) (citing cases that have rejected common law distinctions). In fact, in Sheets, four members of this court favored taking a first step down that path by abolishing the distinction between invitee and licensee. Id. at 606. That position, however, did not gain the support of a majority of the court, and premises liability in Iowa remains dependent on the status of the plaintiff. Richardson v. Commodore, Inc., 599 N.W.2d 693, 698 n. 3 (Iowa 1999).
The present case presents a different question than that presented in Sheets. In this case, we are asked to impose upon landowners a duty of reasonable care with respect to trespassers — persons who enter the landowner’s property without the express or implied consent of the landowner. Although, as already noted, a few courts have abandoned all classifications with respect to landowner liability, the majority of courts have retained the special duties of a property owner to a trespasser. We will briefly review the position of other courts on this issue, not because the law is a popularity contest where the side with the most votes wins, but because the judgment *77of other jurisdictions reflects, we think, a prevailing belief that the interests of trespassers do not warrant a further reduction in the right of property owners to use their land as they see fit.
The landmark case in which a court first abandoned the common law classifications historically used in premises liability law was Rowland v. Christian, 69 Cal.2d 108, 70 Cal.Rptr. 97, 443 P.2d 561 (1968), abrogated in part by statute as stated in Calvillo-Silva v. Home Grocery, 19 Cal.4th 714, 80 Cal.Rptr.2d 506, 968 P.2d 65, 72 (1998). By the end of the 1970s, seven states had followed California’s lead and five states had not, the latter group choosing instead to retain the traditional rules based on the entrant’s status.1 During that same period six states chose to abolish or modify the distinction made between invitees and licensees, but did not take the same step with respect to trespassers.2 Thus, in the twelve years after Rowland, a total of eleven states rejected California’s rule that the liability of property owners to trespassers should be judged by the same standard as their liability to persons legally on their land.
Since 1980, the rejection of California’s one-rule-fits-all approach has been even more overwhelming. In Rhode Island, the Rhode Island Supreme Court partially overruled its earlier decision that had followed Rowland and held that the traditional rules governing liability to trespassers should be retained. Tantimonico v. Allendale Mut Ins. Co., 637 A.2d 1056, 1057 (R.I.1994), overruling in part Mariorenzi v. DiPonte, Inc., 114 R.I. 294, 333 A.2d 127, 131-32 (1975). In addition, the state legislatures in California and Colorado abrogated or partially abrogated court decisions adopting a negligence standard for all premises liability actions. In Colorado, the legislature passed a statute that reinstated a classification-based system of liability for landowners. See Colo.Rev.Stat. § 13-21-115 (1997). In California, in response to cases in which trespassing criminals had recovered for injuries incurred during their unlawful intrusions, the state legislature .enacted a law that limited landowners’ liability to trespassers who were on the property to commit a crime, essentially reinstating the common law duty in such cases. See 1985 Cal. Stat. ch. 1541, § 1 (codified at Cal. Civil Code § 847 (West 2002)).
*78In addition to those jurisdictions retreating from a prior, wholesale adoption of negligence principles, eight states refused to change their conventional principles of trespasser liability, even though they judicially abolished or modified the distinction between an invitee and a licensee.3 Additionally, two states, Maryland and Oklahoma, decided to retain their common law rules governing liability to trespassers, but left open the question whether they would discard the invitee and licensee classifications. Murphy v. Baltimore Gas & Elec. Co., 290 Md. 186, 428 A.2d 459, 463 (1981), overruled in part on other grounds by Baltimore Gas & Elec. Co. v. Flippo, 348 Md. 680, 705 A.2d 1144, 1151 (1998); Lohrenz v. Lane, 787 P.2d 1274, 1276-77 (Okla.1990); see Abbott v. Wells, 11 P.3d 1247, 1248 (Okla.2000) (applying status analysis to invitee in premises liability case). Finally, seven more states chose to maintain the common law rules making the duty owed by a landowner dependent on the status of the injured party.4
In stark contrast to this widespread rejection of negligence principles in trespasser cases, only one state since the 1970s has joined the minority position, abandoning all classifications.5 Moody v. Manny’s Auto Repair, 110 Nev. 320, 871 P.2d 935, 942 (1994).
In summary, presently six states use a negligence standard to govern trespasser liability; twenty-nine states have declined the opportunity to change their rule in such cases; and two state legislatures have reinstated the common law trespasser rule after it had been abolished by court decision. Given the fact that only one court in the last twenty-seven years has abandoned the common law trespasser rule, the so-called “trend” to adopt a universal standard of care, for premises liability has clearly lost momentum. See Baldwin v. Mosley, 295 Ark. 285, 748 S.W.2d 146, 148 (1988) (“Although a number of jurisdictions during' the 1970⅛ indicated a willingness to discard the legal distinctions between licensees and invitees, that abolition movement has since lost its steam.”); Lohrenz, 787 P.2d at 1276 (stating “a number of courts which have more recently considered the issue[ ] have expressed continued adherence to the common law principles of duty based on status as a proper balance between the rights of a landowner and those of the general public”); Tantimonico, 637 A.2d at 1058, 1060 (noting that “by the late seventies an increasing number of courts had specifically rejected Rowland ” *79and that “[t]he more recent trend in premises-liability law is to uphold the traditional common-law categories”). Keeton, in his treatise on torts, suggests that courts are acquiring “a more healthy skepticism toward invitations to jettison years of developed jurisprudence in favor of beguiling legal panacea.” Prosser on Torts § 62, at 434.
We think the California approach has failed to gain favor, at least with respect to trespasser liability, because the common law rule retains validity in modern day life. See id. (stating “courts are gaining a renewed appreciation for the considerations behind the traditional duty limitations toward trespassing adults”). Land ownership is not limited to the privileged few in modern American society; many, many persons own real property. The private ownership of land continues to be a treasured opportunity, and the interests of landowners are still deserving of consideration. We agree with one treatise writer that in a society such as ours, “it is considered a socially desirable policy to allow a person to use his own land in his own way, without the burden of watching for and protecting those who come there without permission or right.” Id. § 58, at 395. As one court has stated, “It is unreasonable to subject an owner to a ‘reasonable care’ test against someone who isn’t supposed to be there and about whom he does not know.” Wood v. Camp, 284 So.2d 691, 693 (Fla. 1973).
The common law rule is also better suited to achieve a reasonable balance between individual property rights and the interests of a trespasser. Under the common law rule, a landowner knows in advance what his duty is; he must refrain from maliciously or deliberately injuring a trespasser. A duty of reasonable care, in contrast, despite its common usage, is based on a much more amorphous standard, providing little guidance to the landowner. See id. at 694 (“Such vague terminology applied in every circumstance affords no guidelines or distinctions ...; just to say that the rule is ‘reasonable care under the circumstances’ in all instances ignores the responsibility of the law to provide guidance.”); Carter v. Kinney, 896 S.W.2d 926, 930 (Mo.1995) (refusing to abolish common law classifications, stating “[t]o abandon the careful work of generations for an amorphous ‘reasonable care under the circumstances’ standard seems — to put it kindly — improvident”); Tantimonico, 637 A.2d at 1059 (quoting another jurist’s contrast of the common law rule, described as “‘well-settled and reasonable,’ ” with the negligence standard, “ ‘a single vague duty of reasonable care, under which the property owner acts at his peril with no standard by which he can judge his obligations in advance’ ” (citation omitted)). Moreover it is no solace to the landowner, who has spent emotional and monetary resources to defend a meritless suit, that a judge or jury eventually finds no liability. See Wood, 284 So.2d at 694 (noting the assurance that a. jury might well find a landowner has not violated a duty of reasonable care “is a dangerous generality (and expense) to which to ' subject- an owner”). Balanced against the need for a predictable standard by which landowners may govern their conduct is the absence of any right of a trespasser to claim more generous protection since the trespasser comes on the land without the express or implied consent or invitation of the property owner. See Poulin v. Colby College, 402 A.2d 846, 851 n. 5 (Me.1979) (“Whereas both invitees, and licensees enter another’s lands under color of right, a trespasser has no basis for claiming extended protection.”).
In summary, we remain unconvinced that the rights of property owners have so little value in today’s society that *80those rights should be diminished in favor of persons trespassing on another’s land. The common law standard is just as viable today as it was a century ago: a landowner has a duty not to injure a trespasser maliciously or deliberately, and to use reasonable care after the trespasser’s presence becomes known to avoid injuring the trespasser. See Champlin, 249 N.W.2d at 842. This duty strikes an appropriate balance between the interests of the landowner and the trespasser and therefore we decline the plaintiffs invitation to abandon it. We express no opinion on whether the differentiation made between invitees and licensees remains viable.
V. Disposition.
We conclude the district court applied the correct legal principles in determining that the defendant was entitled to judgment as a matter of law. Because the plaintiff claims no other error in the court’s ruling, we affirm.
AFFIRMED.
All justices concur except LAVORATO, C.J., who concurs specially and LARSON, J., who joins this concurrence. STREIT, J., concurs specially by a separate opinion.. Compare Webb v. City & Borough of Sitka, 561 P.2d 731, 733 (Alaska 1977) (abolishing classifications), abrogated in part by statute as stated in University of Alaska v. Shanti, 835 P.2d 1225, 1228 n. 5 (Alaska 1992); Mile High Fence Co. v. Radovich, 175 Colo. 537, 489 P.2d 308, 312-13 (1971) (same), abrogated in part by statute as stated in Bath Excavating & Constr. Co. v. Wills, 847 P.2d 1141, 1145 & n. 8 (Colo.1993); Pickard v. City & County of Honolulu, 51 Haw. 134, 452 P.2d 445, 446 (Haw.1969) (same); Cates v. Beauregard Elec. Coop., Inc., 328 So.2d 367, 370-71 (La.1976) (same); Ouellette v. Blanchard, 116 N.H. 552, 364 A.2d 631, 634 (1976) (same); Basso v. Miller, 40 N.Y.2d 233, 386 N.Y.S.2d 564, 352 N.E.2d 868, 872 (1976) (same); Mariorenzi v. DiPonte, Inc., 114 R.I. 294, 333 A.2d 127, 131-32 (1975) (same), overruled in part by Tantimonico v. Allendale Mut. Ins. Co., 637 A.2d 1056, 1057 (R.I.1994), with McMullan v. Butler, 346 So.2d 950, 952-53 (Ala.1977) (refusing to abandon common law distinctions); Bailey v. Pennington, 406 A.2d 44, 47-48 (Del.1979) (same); Mooney v. Robinson, 93 Idaho 676, 471 P.2d 63, 65 (1970) (same); Di Gildo v. Caponi, 18 Ohio St.2d 125, 247 N.E.2d 732, 736 (1969) (same); Tjas v. Proctor, 591 P.2d 438, 441 (Utah 1979) (same).
. See Wood v. Camp, 284 So.2d 691, 693, 695 (Fla.1973); Poulin v. Colby College 402 A.2d 846, 851 (Me.1979); Mounsey v. Ellard, 363 Mass. 693, 297 N.E.2d 43, 51-52 & n. 7 (1973); Peterson v. Balach, 294 Minn. 161, 199 N.W.2d 639, 642 (1972); O’Leary v. Coenen, 251 N.W.2d 746, 751 (N.D.1977); Antoniewicz v. Reszcynski, 70 Wis.2d 836, 236 N.W.2d 1, 5, 11 (1975).
. Washington Metro. Area Transit Auth. v. Ward, 433 A.2d 1072, 1073-74 (D.C.1981); Jones v. Hansen, 254 Kan. 499, 867 P.2d 303, 310 (1994); Heins v. Webster County, 250 Neb. 750, 552 N.W.2d 51, 57 (1996); Ford v. Bd. of County Comm’rs, 118 N.M. 134, 879 P.2d 766, 770 (1994); Nelson v. Freeland, 349 N.C. 615, 507 S.E.2d 882, 892 (1998); Hudson v. Gaitan, 675 S.W.2d 699, 703 (Tenn.1984), overruled in part on other grounds by McIntyre v. Balentine, 833 S.W.2d 52, 54, 57 (Tenn.1992); Mallet v. Pickens, 206 W.Va. 145, 522 S.E.2d 436, 446 (1999); Clarke v. Beckwith, 858 P.2d 293, 296 (Wyo.1993).
. Baldwin v. Mosley, 295 Ark. 285, 748 S.W.2d 146, 148 (1988); Morin v. Bell Ct. Condo. Ass’n, Inc., 223 Conn. 323, 612 A.2d 1197, 1201 (1992); Kirschner v. Louisville Gas & Elec. Co., 743 S.W.2d 840, 844 (Ky.1988); Little v. Bell, 719 So.2d 757, 762 (Miss.1998); Carter v. Kinney, 896 S.W.2d 926, 930 (Mo.1995); Vega v. Piedilato, 154 N.J. 496, 713 A.2d 442, 449 (1998); Tincani v. Inland Empire Zoological Soc’y, 124 Wash.2d 121, 875 P.2d 621, 624 (1994).
. The state of Montana has on occasion been included in lists of states abolishing classifications as the basis for premises liability. While it is true the court has abandoned status-based liability rules, the Montana Supreme Court’s decision to do so was based on a state statute that "prevented [the court] from distinguishing" between classes of injured parties. See Limberhand v. Big Ditch Co., 218 Mont. 132, 706 P.2d 491, 496 (1985).