These consolidated appeals concern third-party crimes on business property. Georgia’s premises statute imposes on proprietors a duty to protect invitees from reasonably foreseeable crimes. Foreseeability turns on all relevant circumstances: similar prior crimes are probative but not required, and ordinarily the jury decides unless no rational juror could find for the plaintiff. At CVS, a customer was shot in a parking-lot robbery; the jury assigned 95 percent fault to CVS, 5 percent to the customer, and none to the shooter. Because instructions required apportionment of negligence, the Court affirmed: an intentional shooter may be non-negligent. At Pappas, a parking-lot shooting killed Anthony Welch; evidence of prior break-ins and nearby armed crimes raised a jury question. The Court reversed the no-foreseeability ruling and remanded. In Welch’s related case against security contractor Tactical, the Court held a contractor may owe a tort duty under Restatement § 324A for negligent performance of voluntarily undertaken security services; it vacated and remanded. McMillian, joined by LaGrua, objected to the broader foreseeability rule. LaGrua separately raised policy concerns, while Pinson emphasized the narrow apportionment holding.