The general rule in Virginia is that there is no common law duty for an owner or occupier of land either to warn or to protect an invitee on his property from the criminal act of a third party. Yuzefovsky, 261 Va. at 106, 540 S.E.2d at 139. "[T]here are narrow exceptions to this rule," but the application of those exceptions "is always fact specific and, thus, not amenable to a bright-line rule for resolution." Id. However, before an exception to the general rule can apply so as to impose a potential duty upon the owner of land, the facts "must establish that there is a special relationship, either between the [owner of land] and the [invitee] or between the third party criminal actor and the [owner of land]." Id. at 107, 540 S.E.2d at 139. The relationship between innkeeper and guest has long been recognized by the common law as constituting just such a special relationship.
