— the person who caused the harm has a history of violence;15 or
— the person who caused the harm and their victim had previously had a confrontation.16
 The facts in Van Hartevel are analogous to those in this
case. In Van Hartevel, the B.C. Supreme Court held the owner of
a building liable for a physical assault on a tenant by the building
manager. The building manager had a criminal record, including
two prior convictions for assault. Months prior to the incident,
based on previous interactions with him, the tenant wrote to the
building’s owner asking that the manager be kept away from
him. The court found that the owner knew about the manager’s
violent history and prior convictions and about his previous confrontations with the tenant. In these circumstances, the court
concluded that owner could have reasonably foreseen the risk of
physical injury to the tenant by the manager, and that the owner
was therefore liable in negligence under the B.C. Occupiers Liability Act.17
 Similarly, in Millar, an occupier was found liable for
a physical altercation between her brother and her neighbours.
Jean Millar owned a rental property next to her own home. The
tenants caused damage to the property and sometimes became
very drunk, to the point where she had called the police several
times. The tenants also had confrontations with Jean’s brother,
 On one particular night, the tenants were drinking heavily
and became belligerent. They made abusive telephone calls to Ms.
Millar and she became concerned for her safety. Instead of calling
the police, she asked her brother to come over. After he
arrived, he got into a physical fight with the tenants and suffered
serious injuries. The court found that Ms. Millar was negligent
and had breached her duty of care under the OLA by calling her
brother instead of the police:
She did not explain to him the true nature of the situation and the danger
inherent in it. I find that if she had called the police rather than her brother,
the police would have responded in a timely and prompt manner, as they did
when they were called after the fact, and Mr. Millar would not have suffered
15 Van Hartevelt v. Grewal,  B.C.J. No. 906, 2012 BCSC 658 (“Van
Hartevelt”), at para. 67.
16 Millar v. Waring,  O.J. No. 1865, 176 A.C.W.S. (3d) 1166 (S.C.J.)
(“Millar”), at para. 224; Van Hartevelt, at para. 73.
17 R.S.B.C. 1996, c. 337.