dissenting, joined by CATHELL, J., and HARRELL, J.
I would affirm the judgment of the Circuit Court for Baltimore County and the judgment of the Court of Special Appeals. See Hemmings v. Pelham Wood, 144 Md.App. 311, 797 A.2d 851 (2002). The Court of Special Appeals held that the landlord did not owe a duty to protect the tenant from criminal activity committed by third persons within the premises demised to the tenant, an area in which the landlord was no longer able to exert control. I agree.
Plaintiff, Suzette Hemmings, brought a wrongful death and survival action alleging lack of adequate security and lighting in and around the leased premises as the proximate cause of her husband’s death. In plaintiffs second amended complaint, plaintiff alleged as follows:
¶ 6. Prior to June 13, 1998, complaints had been made notifying the Defendants of criminal activity in and around the Pelham Wood Apartments and of the vulnerability of specific buildings which back up to a wooded area which is completely dark.
¶ 7. Defendants were aware of the specific vulnerability of 5 Lynfair Court based on prior criminal incursions into that building, several of which required the response of the Baltimore County Police Department.
¶ 8. Defendants were aware and/or had reason to be aware of the criminal activity in and around Pelham Wood Apartments and/or had reason to be aware of the dangerous conditions that existed.
¶ 9. Despite the Defendants’ knowledge of the criminal activity and the dangerous conditions that existed in and around Pelham Wood Apartments and, the Defendants’ ability to take steps to ensure the safety of the premises and its tenants, the Defendants did nothing to eliminate the danger or enhance the safety of its tenants.
On the wrongful death and survival claim filed by Ms. Hemmings against her landlord, summary judgment in favor of the landlord was entered properly by the Circuit Court because *550the plaintiff failed to establish sufficient evidence to state a cause of action in negligence. There is no duty on the part of the landlord to provide security within the premises demised to the tenant to protect the tenant from criminal violence perpetrated by third persons.1 Neither is there a duty on the part of the landlord to ensure the safety of the premises or its tenants.
The majority concludes that “the facts of the present case show that the Landlord provided exterior lighting at Pelham Wood as a security measure intended to deter criminal activity. Thus, it had a duty to adequately maintain that lighting.” Maj. op. at 28. Although the majority refers to evidence from tenants that there was no light fixture outside the wall of a particular apartment or that it was very dark outside, there is absolutely no evidence in this record that the Landlord received a complaint or notice that the light was not functioning. It is important to note at the outset that the adequacy of door locks, alarms or “charley bars” is not at issue in this case. The majority quotes in great detail provisions from the lease related to locks on the doors within the leasehold and the charley bar on the sliding glass door. The record reflects no complaints from the plaintiff-tenant or her decedent spouse to the landlord-defendant that the locks were inoperable or deficient or that the charley bar needed repair or replacement. See maj. op. at 2-6. Apparently recognizing that there was absolutely no notice of any problem with these security devices, the majority abandons, and rightfully so, these devices as a basis for any duty on the landlord’s part to protect the tenant from harm occurring within the apartment.2
*551The entire basis of the majority opinion rests upon inade- - quate lighting in the rear of the apartment building. The majority holds that because the landlord provided exterior lighting at Pelham Wood as a security measure intended to deter criminal activity, it had a duty to adequately maintain that lighting. See maj. op. at 28. From this duty to maintain adequate lighting in the common area, the majority makes the unjustified leap in logic that somehow the landlord is then responsible for violent criminal activity that occurred within the demised premises and not within the common area.3
It has long been the law in this State that there is no general duty to protect another person from crime. That rule applies to the ordinary relationship between landlord and *552tenant, although a duty may exist under special circumstances. See Scott v. Watson, 278 Md. 160, 166, 359 A.2d 548, 552 (1976) (holding that there is no special duty imposed upon the landlord to protect his tenants against crimes perpetrated by third parties on the landlord’s premises). In the absence of statute or special relationship, there is no duty to protect another from harm. Id., 359 A.2d at 552. The general rule is that the landlord’s .duty to protect tenants or other persons on the leased property from the criminal acts of third parties does not arise unless there is a reasonably foreseeable risk of harm. See Annot., Landlord Liability Criminal Acts, 43 A.L.R. 5th 207, 406-08, 436-39 (1996). The commentators in that annotation note as follows:
“The question whether a landlord is obligated to protect tenants against criminal activities of third parties is a specific facet of the more general issue as to whether a private person is under a duty to protect another against criminal conduct. As a general principle, and in the absence of statutes or of special relationships or circumstances ... a private person has no duty to protect another from a criminal assault or a willful act of violence of a third person, but that the duty to protect another from criminal attack may voluntarily be assumed by contract, and if it is, the law will recognize and enforce such a duty....
Traditionally, courts have found that the mere relation of landlord and tenant falls within the general rule and does not impose upon the landlord a duty to protect the tenant against criminal activities of third parties, ordinarily reasoning that the liability of a landlord for injuries or damages resulting from such activities must' be predicated either upon the breach of a contractual or statutory obligation, or upon the foreseeability, under the circumstances, of the criminal occurrence.”
Id. at 241.
A landlord is not the insurer of the safety of persons within the demised premises, or for that matter, in the common areas of the property. The duty of the landlord is a duty of reasonable care to protect against known or reasonably fore*553seeable risks. A landlord is not required to take precautions against criminal conduct committed by third persons which the landlord has no reason to anticipate. Nor is the landlord responsible for attacks that are not caused by the landlord’s action or inaction. In the instant case, it is clear that the landlord did not owe plaintiff a duty to provide her with lighting that would inhibit or discourage break-ins by third parties into her apartment.
The plaintiff and majority’s theory that there is potential liability arising from a breach of duty by the landlord because the landlord either undertook to light the back area and failed to maintain the lighting properly, or never undertook to light the back area and it should have done so, is not persuasive. Nor is the majority’s theory that the single light in the rear of the apartment building was placed there by the landlord for security purposes. The plaintiff has not shown that the landlord did anything that could reasonably be considered as having voluntarily undertaken to provide protection from criminal activity by third parties within the leased premises. The one light in the rear of the building cannot be construed as a voluntary undertaking to provide security within the apartments; a failure to provide lighting in the rear of the complex cannot, and has not, been considered in this State as a basis to impose liability for injuries occurring within the demised premises. Even if the landlord did provide illumination in the common area, “the furnishing of outside lighting is commonplace and furnished by virtually every landlord to every tenant in a facility such as is involved here. It cannot reasonably be regarded as the assumption of a duty to protect against criminal acts.” Rowe v. State Bank of Lombard, 125 Ill.2d 203, 126 Ill.Dec. 519, 531 N.E.2d 1358, 1365 (1988).
The majority relies primarily on the cases of Matthews v. Amberwood, 351 Md. 544, 719 A.2d 119 (1998) and Scott, 278 Md. 160, 359 A.2d 548.4 Neither case supports the holding *554that the landlord has a duty to protect the tenant from criminal activity within the demised premises.
The majority relies on Scott, 278 Md. at 165, 359 A.2d at 552, as support for its conclusion that a duty exists. Scott is inapposite. The intermediate appellate court, in the present case, pointed out that Scott was inapposite to the plaintiffs claim:
“We cite Scott v. Watson as it establishes the basic principles of Maryland law with regard to the duty owed by a landlord in protecting the safety of his or her tenant. In Scott, however, the Court of Appeals was presented with the issue of whether the landlord of an urban apartment complex had a duty to protect tenants from the criminal acts of third parties committed in common areas within the landlord’s control. The Court ultimately concluded that a duty would be imposed on the landlord only if the landlord had knowledge of increased criminal activity and if the premises were thereby rendered unsafe. Scott, however, is not controlling because the case sub judice involves an act that occurred within the leased premises. We deem this to be an overriding distinction.”
Hemmings, 144 Md.App. at 317 n. 4, 797 A.2d at 855 n. 4.
Scott involved the murder of a tenant in the common area, an underground parking garage. Under the Maryland Uniform Certification of Questions of Law Act, Maryland" Code (1974, 2002 RepLVol.), § 12-601 through § 12-613 of the Courts and Judicial Proceedings Article, and Maryland Rule 8-305, this Court considered “[wjhether a duty is imposed upon the landlord to protect his tenants from criminal acts of third parties where he has knowledge of increasing criminal *555activity on the premises, or in the immediate neighborhood.” Scott, 278 Md. at 168, 359 A.2d at 553. We said:
“The duty of the landlord to exercise reasonable care for the safety of his tenants in common areas under his control is sufficiently flexible to be applied to cases involving criminal activity without making the landlord an insurer of his tenant’s safety. If the landlord knows, or should know, of criminal activity against persons or property in the common areas, he then has a duty to take reasonable measures, in view of the existing circumstances, to eliminate the conditions contributing to the criminal activity. We think this duty arises primarily from criminal activities existing on the landlord’s premises, and not from knowledge of general criminal activities in the neighborhood. Every person in society is subject to the risk of personal injury or property damage from criminal activity, both inside and outside his abode. The risk obviously varies with the time and locale. Since the landlord can affect the risk only within his own premises, ordinarily only criminal acts occurring on the landlord’s premises, and of which he knows or should have known (and not those occurring generally in the surrounding neighborhood) constitute relevant factors in determining, in the particular circumstances, the reasonable measures which a landlord is under a duty to take to keep the premises safe.”
Id. at 169, 359 A.2d at 554 (first and third emphases added). Scott does not stand for the proposition that the landlord is responsible for personal injury to a tenant as the result of criminal activity that occurs within the premises under control of the tenant and outside of the common areas.5
Matthews provides no support for the plaintiff. In Matthews, a sixteen-month-old child, the son of a social guest of *556the particular tenant, was killed by the host’s pit bull. The tenant’s lease provided that pets were prohibited on the premises. We held that the pit bull in question was an extremely dangerous condition within the tenant’s apartment and that the landlord retained control over the presence of the dog in the leased premises by virtue of the “no pet” clause in the lease. Matthews, 351 Md. at 558, 719 A.2d at 125. We said:
“We do not hold that a landlord’s retention in the lease of some control over particular matters in the leased premises is, standing alone, a sufficient basis to impose a duty upon the landlord which is owed to a guest on the premises. This Court has employed a balancing test to determine whether a duty of reasonable care should be imposed in particular circumstances. ‘[U]ltimately, the determination of whether a duty should be imposed is made by weighing the various policy considerations and reaching a conclusion that the plaintiffs interests are, or are not, entitled to legal protection against the conduct of the defendant.’ In the instant case, the various policy considerations that need to be weighed are the general understanding that a tenant is primarily in control of the leased premises and the sanctity of a tenant’s home, including her ability generally to do as she sees fit within the privacy thereof, against the public safety concerns of permitting that same tenant to harbor an extremely dangerous animal that will foreseeably endanger individuals inside and outside the walls of the leased premises, the degree of control maintained by the landlord, the landlord’s knowledge of the dangerous condition, and the landlord’s ability to abate the condition. We, like the majority of courts addressing this issue [landlord’s liability for pit bull attacks] in other states, believe that the balance should be struck on the side of imposing a duty on the landlord which is owed to guests on the premises.”
Id. at 565-66, 719 A.2d at 129 (Citations omitted).
The only way the majority can reach their desired result is to cobble together the line of cases in Maryland imposing a *557duty for liability for physical harm which occurred in the common areas with the line of cases finding liability for demised premise damage resulting from a cause originating in the common area. See maj. op. at 23. This is a novel theory, unsupported by any authority or case law in the country.
Some courts have found that, based on a voluntary assumption theory, a landlord’s duty arises from an express or implied promise to provide security. See e.g., Phillips v. Chicago Housing Authority, 89 Ill.2d 122, 59 Ill.Dec. 281, 431 N.E.2d 1038, 1041 (1982) (citing Nelson v. Union Wire Rope Corp., 31 Ill.2d 69, 199 N.E.2d 769, 774 (1964)). Section 324A of the Restatement (Second) of Torts (1965) states as follows:
“One who undertakes, gratuitously or for consideration, to render services to another which he should recognize as necessary for the protection of a third person or his things, is subject to liability to the third person for physical harm resulting from his failure to exercise reasonable care to protect his undertaking, if
(a) his failure to exercise reasonable care increases the risk of such harm, or
(b) he has undertaken to perform a duty owed by the other to the third person, or
(c) the harm is suffered because of reliance of the other or the third person upon the undertaking.”
Section (c) has been interpreted to mean that “[wjhere the reliance of the other, or of the third person, has induced him to forego other remedies or precautions against such a risk, the harm results from the negligence as fully as if the actor had created the risk.” See Pippin v. Chicago Housing Authority, 78 Ill.2d 204, 35 Ill.Dec. 530, 399 N.E.2d 596, 600 (1979) (quoting Restatement (Second) of Torts § 324A cmt. e). Without relying explicitly upon § 324A, the majority appears to find a duty on the landlord’s part based upon the landlord having provided for outdoor lighting in the common area and the failure to maintain the lighting. See maj. op. at 28.
The question of whether a landlord’s provision of security measures can give rise to liability for harm to tenants, within *558the demised premises, that results from a failure to maintain those measures is one of first impression in the State. Other states have addressed the question, -with varying results. See, e.g., Walls v. Oxford Mgmt. Co., 137 N.H. 653, 633 A.2d 103, 106-07 (1993) (“[A] landlord who undertakes, either gratuitously or by contract, to provide security will thereafter have a duty to act with reasonable care.”); Sharp v. W.H. Moore, Inc., 118 Idaho 297, 796 P.2d 506, 509 (1990) (“A landlord, having voluntarily provided a security system, is potentially subject to liability if the security system fails as a result of the landlord’s negligence.”); Feld v. Merriam, 506 Pa. 383, 485 A.2d 742, 747 (1984) (“[A] landlord may ... incur a duty voluntarily or by specific agreement if to attract or keep tenants he provides a program of security.”). But see, e.g. Hall v. Rental Mgmt., Inc., 323 Ark. 143, 913 S.W.2d 293, 297 (1996) (holding that a landlord’s implementation of “modest, conscientious measures” such as safety lighting, evening patrols, and communication with residents regarding suspicious activities, “do not rise to such a level that [the landlord] assumed a duty to protect its tenants from criminal attacks by third parties”).
In several states where the duty to maintain security features external to the demised premises gives rise to liability for harm to tenants, the duty imposed is limited to the extent of the security measures undertaken. See Walls, 633 A.2d at 107; Feld, 485 A.2d at 747 (“A tenant may rely upon a program of protection only within the reasonable expectations of the program. He cannot expect that a landlord will defeat all the designs of felonry. He can expect, however, that the program will be reasonably pursued and not fail due to its negligent exercise.”). In Funchess v. Cecil Newman Corp., 632 N.W.2d 666 (Minn.2001), the Supreme Court of Minnesota noted:
“We are not inclined to establish a rule that would discourage landlords from improving security. Transforming a landlord’s gratuitous provision of security measures into a duty to maintain those measures and subjecting the landlord to liability for all harm occasioned by a failure to *559maintain that security would tend to discourage landlords from instituting security measures for fear of being held liable for the actions of a criminal. This limitation on the extent of the duty to maintain security measures leads us to conclude that any duty [the landlord] might have had is not of the type to give rise to liability for Haynes’ death.”
Id. at 675.
Courts have generally held, based on public policy, that it is not fair to impose upon the landlord a duty to protect the tenant from criminal activity within the demised area. See Bartley v. Sweetser, 319 Ark. 117, 890 S.W.2d 250, 252 (1994); R. Schoshinski, American Law of Landlord and Tenant, 217 (1980). The reason for the rule has been stated as follows:
“ ‘Judicial reluctance to tamper with the common law concept of the landlord-tenant relationship, the notion that the act of a third person in committing an intentional tort or crime is a superseding cause of harm to another ...; the often times difficult problem of determining foreseeability of criminal acts; the vagueness of the standard which the landlord must meet; the economic consequences of the imposition of the duty; and the conflict with public policy allocating the duty of protecting citizens from criminal acts to the government rather than the private sector.’ ”
Id. (quoting Kline v. 1500 Massachusetts Ave. Apartment Corp., 439 F.2d 477, 481 (D.C.Cir.1970)). Although this Court has been willing to consider changes to the common law, recognizing that the law is not static, the other reasons set forth by Professor Schoshinski are persuasive. This view is consistent with the Restatement (Second) of Torts § 448 (1965), which reads as follows:
“The act of a third person in committing an intentional tort or crime is a superseding cause of harm to another resulting therefrom, although the actor’s negligent conduct created a situation which afforded an opportunity to the third person to commit such a tort or crime, unless the actor at the time of his negligent conduct realized or should have realized the likelihood that such a situation might be created, and that a *560third person might avail himself of the opportunity to commit such a tort or crime.”
Thus, foreseeability of a risk of harm is the primary basis for imposing a duty, but, the question is not simply whether a criminal event is foreseeable, but whether a duty exists to take measures to guard against it. See Smith v. Dodge Plaza, 148 Md.App. 335, 346-55, 811 A.2d 881, 888-93 (2002). Although the foreseeability of a plaintiffs injury is important in the determination of whether a duty exists, the imposition of a duty does not depend upon foreseeability alone. As Dean Prosser stated, “[I]t should be recognized that ‘duty is not sacrosanct in itself, but is only an expression of the sum total of those considerations of policy which lead the law to say that the plaintiff is entitled to protection.” Prosser and Keeton on Torts § 53 (5th ed.1984). Whether a duty exists depends on the relationship of the parties, consideration of the likelihood of injury and nature of the risk, the public interest in the proposed solution, the burden to guard against it, and the consequences of placing that burden upon the defendant.6 See Rosenblatt v. Exxon, 335 Md. 58, 77, 642 A.2d 180, 189 (1994); Ashburn v. Anne Arundel County, 306 Md. 617, 627-28, 510 A.2d 1078, 1083 (1986). Writing for the panel in Dodge Plaza, Judge Rodowsky applied the balancing approach set out in Matthews, “under which the foreseeable risk is compared to a number of factors, including ‘the landlord’s ability to abate the condition.’ ” Dodge Plaza, 148 Md.App. at 351, 811 A.2d at 891 (quoting Matthews, 351 Md. at 566, 719 A.2d at 129).
Whether the landlord retains responsibility for actions which occur within the leased premises under other circumstances is not an issue before this Court. Those circumstances have yet to be defined. See, e.g., Frances T. v. Village Green Owners Ass’n, 42 Cal.3d 490, 229 Cal.Rptr. 456, 723 *561P.2d 578 (1986) (finding allegation of negligence sufficient based on condominium association’s duty to provide exterior lighting, where tenant/victim made repeated requests to improve lighting for security, installed additional lighting herself, and was ordered by the association to remove her additional lighting). What is clear to me, and is before this Court, is that the failure to maintain adequate lighting in the common area does not make a murder within the leased premises foreseeable. The Court of Special Appeals rejected plaintiffs arguments. Judge Arrie Davis, writing for the panel, cogently reasoned as follows:
“ ‘The basic elements necessary for a cause of action in negligence “are a duty or obligation which the defendant is under to protect plaintiff from injury, a failure to discharge that duty, and actual loss or injury to the plaintiff proximately resulting from that failure.” ’ Scott v. Watson, 278 Md. 160, 165, 359 A.2d 548 (1976)(quoting Peroti v. Williams, 258 Md. 663, 669, 267 A.2d 114 (1970)). A landlord is obligated to use reasonable and ordinary care to keep common areas safe. Id. Because a landlord is not an insurer of the safety of its tenants, he or she is not ordinarily liable to a tenant or guest of a tenant for injuries from a hazardous condition in the leased premises that comes into existence after the tenant has taken possession. Marshall v. Price, 162 Md. 687, 161 A. 172 (1932). This rule also applies to criminal acts of third parties; ‘there is no special duty imposed upon the landlord to protect his [or her] tenants against crimes perpetrated by third parties on the landlord’s premises.’ Scott, 278 Md. at 166, 359 A.2d 548. However, when it can be illustrated that the landlord had knowledge of increased criminal activity on the premises, a duty is imposed on the landlord to undertake reasonable measures to keep the premises secure.7 Id. at 165, 359 A.2d 548.”
*562Hemmings, 144 Md.App. at 317-18, 797 A.2d at 855. The Court of Special Appeals concluded:
“From the facts presented, a fact finder would be constrained to conclude that there could be no showing that appellees’ failure to maintain the common areas was the proximate cause of the fatal event. Consequently, the grant of summary judgment was proper.”
Id. at 323-24, 797 A.2d at 859. I agree with the Court of Special-Appeals and would affirm.
Accordingly, I respectfully dissent. Judge Cathell and Judge Harrell have authorized me to state that they join in this dissenting opinion.
. The majority recognizes and iterates the proper test for summary judgment and that the existence of duty in a negligence case is a question of law for the court. Maj. op. at 12. See also Grimes v. Kennedy Krieger, 366 Md. 29, 114-15, 782 A.2d 807, 858-59 (2001) (Raker, J., concurring).
. The analysis and the result in this case might well be different if the basis for the landlord’s liability was the landlord retaining control over aspects of the demised premises and particularly the locks and any alarm devices. It is important to note that ¶ 7 of the rules and *551regulations of the lease restricting tenant from changing or installing additional locks on the doors without the landlord's written permission is not at issue in this case. Where the landlord insists on control over the decisions as to changing or maintaining locks or security devices, and permission has been withheld or the tenant has given notice and the landlord has not responded, the result may be different if injury occurs.
Many courts have recognized that “by retaining control over aspects of the premises such as door and window locks or alarm devices which directly relate to security, the landlord faces potential liability when the circumstances are such that a reasonable man would realize that a failure to act would render one relying on those actions susceptible to criminal acts.” Lay v. Dworman, 732 P.2d 455, 459 (Okla.1986). The Oklahoma court found that a complaint stated a cause of action for injury to a tenant which occurred within the leased apartment where the landlord retained exclusive control over the door locks and the tenant had reported the broken lock. Id. at 458-59. The court found that:
“These principles appear to form the foundation for the landlord's liability in other jurisdictions in cases involving criminal acts within the rented premises. The element of foreseeability in these cases has been found from a history of criminal activity in the apartment complex or building, or strictly from the nature of the defect in the premises.”
Id. at 459.
. Under the plaintiff's theory and the majority’s reasoning, it is solely the lack of "adequate” lighting which forms the basis for liability. Following the majority's reasoning, the lack of adequate lighting could form the basis of liability in the first place, as well as failure to adequately maintain existing lighting.
. I joined the majority in Matthews, and still believe that case was decided properly. If this case is the logical extension of Matthews, then I would join Judges Cathell and Harrell to overrule Matthews. (Judge *554Harrell was not a member of this Court when Matthews was decided.) In my view, the outcome in Matthews was controlled by the fact that the tenant harbored a dangerous animal, known to the landlord, in violation of the lease agreement between the landlord and the tenant and thus within the landlord’s ability to control the activity within the demised premises.
. The majority restates and embraces Ms. Hemmings' argument “that Scott should apply to the instant case because we have held that a landlord may be liable when a tenant suffers a foreseeable injury in the leased premises caused by a landlord’s failure to use reasonable care for the tenant's safety in the common areas.” Maj. op. at 21. Ms. Hemmings’ premise is wrong. Scott dealt with injury in the common area and Ms. Hemmings misstates the holding.
. Were we to hold that the failure to maintain, or install the lighting subjects the landlord to liability for all violent crime committed by a third parly within the tenant’s apartment and in a location beyond the control of the landlord, we would discourage the landlord from initiating extra lighting for fear of being held liable for the actions of a criminal.
. The duty to keep “the premises secure” in this context means the common areas, not the demised premises.