What is the "high crime area" factor?

110 Cal.App.4th 171, 177.) As our high court has explained, "The 'high crime area' factor is not an 'activity' of an individual. Many citizens of this state are forced to live in areas that have 'high crime' rates or they come to these areas to shop, work, play, transact business, or visit relatives or friends. The spectrum of legitimate human behavior occurs every day in so-called high crime areas. As a result, this court has appraised this factor with caution and has been reluctant to conclude that a location's crime rate transforms otherwise innocent-appearing circumstances into circumstances justifying the seizure of an individual. [Citations.]" (People v. Bower (1979) 24 Cal.3d 638, 645, superseded by statute on other grounds, as stated in People v. Lloyd (1992) 4 Cal.App.4th 724, 733; see also People v. Loewen (1983) 35 Cal.3d 117, 124.)