Can a landlord be held liable for damages arising from criminal activity committed off of the landlord's property by drug dealers and their customers against third parties?

Relying on Martinez v. Pacific Bell (1990) 225 Cal.App.3d 1557, 275 Cal.Rptr. 878, and other cases refusing to hold defendants liable for the criminal acts of third persons, petitioners contend that a landlord should not be liable for damages resulting from criminal activity or tortious acts committed off of the landlord's property by drug dealers and their customers against third parties when neither the dealers, their customers, nor the third parties are the landlord's tenants.