Another Remarkable Torts Case:

The case -- Kelly v. Kroger Co., 484 F.2d 1362 (10th Cir. 1973) -- is from the 1970s, but it continues to be cited, and its logic is consistent with the logic of other recent negligent provocation arguments, so I thought I'd pass it along:

[D]ecedent was a customer in defendant’s store in Kansas City, Kansas, when a holdup took place. The robbers entered the front of the store with guns, took money from the checkout stands, and then ordered the store manager to open the safe in his office. The opening of the safe caused an alarm to sound at the Kansas City police department, but not at the store.

Several police officers responded immediately to their alarm, and when they entered the front door, the robber ran to the rear part of the store. The police fired a shot at one of the robbers at this time in the store. The decedent was in the rear of the store, and a robber seized her as a hostage or a shield. As the robber left the store at the front, he forced her with him up the street a block or so as he attempted to escape. The police followed and the robber then shot and killed the decedent. The police then shot at the robber as he ran some distance, and captured him.

The attempted robbery took place about 1:30 in the afternoon. During the course of the robbery, the store employees did not sound any other alarm nor attempt to direct or assist the police. This store had been robbed about a month before. Some fourteen robberies of grocery stores in the northeastern part of the city, where the store here concerned is located, had taken place in the prior eighteen-month period. An armed guard had been stationed in this store from time to time.

The complaint is based on the theory that the defendant was negligent in store procedure it had adopted to be followed during the course of such a robbery. The negligence alleged is thus the action taken once the holdup was in progress. The allegations are directed particularly to the silent alarm attached to the store safe....

The trial court, in granting summary judgment for the defendant, held in effect that no negligence was stated in the allegations, and even had there been it could not have been the proximate cause of the injury because the consequences could not reasonably have been foreseen....

The standard of care owed to business invitees [under Kansas law] is ... one of “due care to keep the premises reasonably safe” for their use, but the proprietor is not an insurer of their safety.... The defendant had issued a pamphlet to its employees telling them what to do in the event of a holdup. The particular emphasis in the pamphlet was to do nothing to excite or startle the robbers. It stated in part that many robberies are by young persons who might start shooting if something unexpected should happen. The employees were warned particularly not to give any verbal alarm in the street because this would greatly increase the probability of injury. Thus the plaintiff asserts that the triggering of the silent alarm was not in accordance with the instructions given employees, was not a prudent act, and did not show an exercise of due care for the safety of the customers....

[Under Kansas law, it] is perhaps an aspect of “foreseeability,” not so much that a particular incident may occur, but once one is in progress, when the danger to the customer is evident. Thus under this standard if there is an opportunity to comprehend the danger, negligence can then become a jury question.... The same theory is advanced by the plaintiff in his complaint, that is, that the danger to customers and employees of the store during the course of the robbery was apparent, and that the wrong action was taken — action which served to increase the hazard and which in fact caused the injury. Under this theory of the case, the granting of summary judgment was error.

Note that this is not a case claiming that it was negligent not to hire a security guard, or that the security guard was negligent in reacting too aggressively to the robbers, or even that a store employee was negligent in refusing to hand over the money to the robbers (a highly problematic theory, in my view, but I set it aside here). The theory of liability is simply that it was negligent to trigger a silent alarm that called the police.

einhverfr (mail) (www):
Hmmm... So what exactly was the theory of liability?

That the store manager should have told the robbers "sorry, I can't open the safe for you?"

Or that the safe shouldn't have had an alarm on it?
8.13.2009 7:43pm
yankev (mail):
I have not read the case. Does the court discuss supervening cause, in the form of intentional criminal acts of a third party?
8.13.2009 7:44pm
troll_dc2 (mail):
Do you know how the case turned out? The ruling suggests that the only proper conduct of the defendant would have been to do nothing. That cannot really be the law, can it?
8.13.2009 7:44pm
Steve:
Is there some kind of common-law principle that ought to keep this from being a jury question? Is a shopkeeper privileged to alert the police about a crime in progress, even if it arguably endangers his business invitees? Not sure what's wrong with letting the jury decide.
8.13.2009 7:59pm
Gabriel McCall (mail):
The opening of the safe caused an alarm to sound

the danger to customers and employees of the store during the course of the robbery was apparent, and that the wrong action was taken

Leaving aside the question of whether the court's theory is reasonable or valid, it simply doesn't apply to the facts of the case anyway. The theory is that negligence can attach to decisions made in the moment based on currently-evolving circumstances, but the decision to install an alarm on the safe was not made while the burglars were there.
8.13.2009 8:00pm
einhverfr (mail) (www):
Note on EV's analysis:

Note that this is not a case claiming that it was negligent not to hire a security guard, or that the security guard was negligent in reacting too aggressively to the robbers, or even that a store employee was negligent in refusing to hand over the money to the robbers....


It seems to me that this opinion snippet is even more problematic than those cases. It seems that it is alleged:

1) Defendant told employees not to excite or alarm robbers.

2) Defendant placed a silent alarm on the safe in the office.

3) Store manager was told by robbers to open safe he did so, triggering the alarm.

4) Store manager was negligent (and hence business) for triggering alarm.

It seems then the question is then referred to trial, suggesting that one should question whether the store manager should have given the robbers money that was in the safe, should have disarmed the alarm first (possibly located elsewhere, causing the robbers much concern), or whether he acted appropriately.

It seems to me that this sets the bar EXTREMELY low to liability. Fortunately, I can't imagine any jury saying "Sure! Don't cooperate with armed robbers" or even "Tell them you have to disarm the alarm first!" So I can't really understand why summary judgement couldn't be given. Even accepting all the facts alleged by the plaintiff, I have a hard time imagining a rational juror faulting the manager for doing exactly what the robbers told him to do at gunpoint.
8.13.2009 8:05pm
Steve:
I don't believe the silent alarm needs to be taken as a given, as though God had put it in the safe. The argument is "your own instructions to employees acknowledge that it's dangerous to customers to sound an alarm, ergo you shouldn't have a silent alarm that gets triggered during a robbery." I don't see any indication that the plaintiff's theory was that it was reasonable for the defendant to install the alarm but that it should have been disarmed in the middle of a robbery.
8.13.2009 8:17pm
George Weiss (mail) (www):
um...how about a citation?

[Whoops, sorry, added it. -EV]
8.13.2009 8:17pm
Steve:
In other words, I see little difference between this theory and a theory that an employee unreasonably endangered customers by refusing to hand over money. I agree that both theories are problematic, but I don't see how they aren't jury questions. Obviously from the standpoint of the customer, whose primary concern is for his own safety, he prefers that store employees cooperate 100% with the robber and send him on his way - which includes giving him what he asks for, not triggering any alarms that might lead to a shootout with police, etc.

The store can always call the police after the robbery, but here they chose to adopt a policy which alerted the police during a robbery, obviously in hopes of preventing the robbery's successful completion. I might not agree with the theory, but a plaintiff can certainly argue that it was unreasonable for the store to value its money above the safety of its customers. Again I ask - what principle exists in the common law to allow the judge to take this question away from the jury?
8.13.2009 8:22pm
Gabriel McCall (mail):
But according to the fact pattern and legal theory as presented, the alarm IS a given. The court is not saying that it may have been negligent to install the alarm, but rather that it may have been negligent action in the moment to trigger it. But there was no choice available to the person who opened the safe not to trigger the alarm (as I read the opinion); the only way not to trigger it would have been to refuse to open the safe, which could just as easily have been construed as negligence. And if you're in a situation where all options available to you may lead to bad outcomes, I don't see how you can argue that the one chosen is negligent just because it did.
8.13.2009 8:42pm
David Schwartz (mail):
What is the purported theory of liability? That connecting the silent alarm was negligent? Or was it that the employee should have warned the burglars about the silent alarm so as not to put the customers at risk of becoming hostages when the police responded? Or the employee should have simply refused to open the safe because of that risk?

This is a case where beyond question, any liability belongs to the criminals and perhaps arguably to the police. It is inconceivable to me that any liability could attach to the business.

Arguing that the installation of the silent alarm could be negligent is especially absurd. I could see it if the alarm alerted the criminals.
8.13.2009 9:11pm
Steve:
But according to the fact pattern and legal theory as presented, the alarm IS a given.

Based upon what? The opinion states: "The complaint is based on the theory that the defendant was negligent in store procedure it had adopted to be followed during the course of such a robbery." The silent alarm is obviously part of the procedure the store had adopted.

If you want to argue that look, the store had no choice because it had to either trigger the alarm or refuse to open the safe, I have no problem with that argument. But it should be made to the jury.
8.13.2009 9:16pm
Steve:
Arguing that the installation of the silent alarm could be negligent is especially absurd.

Why? It is certainly foreseeable that alerting the police while a robbery is still in progress could lead to a situation that is dangerous for store employees and customers.

Again, I ask if there's some established common-law principle that a shopkeeper has a privilege to summon the police even if it might expose his customers to danger. I'm wondering where all the people are who show up in the constitutional law threads to insist that judges shouldn't just make the law up.
8.13.2009 9:18pm
_quodlibet_:
>>631271

but a plaintiff can certainly argue that it was unreasonable for the store to value its money above the safety of its customers.

But then plaintiff would need to prove defendant's state-of-mind, a difficult task. The store owner/manager can reasonably argue that he installed the alarm to help bring justice to any would-be robbers and that the deterrence effect of this would make his store (and other stores) safer overall because fewer robberies would be attempted.


Again I ask - what principle exists in the common law to allow the judge to take this question away from the jury?

Intervention of third party's criminal actions might, as a matter of law, preclude liability. Also if the liability would stem from the store's communication to the police, then the First Amendment might preclude such liability. The store owner certainly has the right to inform the police that his store is being robbed, so any legal rule that imposes liability for exercising this right would infringe the store owner's rights.
8.13.2009 9:31pm
Gabriel McCall (mail):
For reference, the case is Kelly v. Kroger.
8.13.2009 9:48pm
_quodlibet_:
>>631296

Arguing that the installation of the silent alarm could be negligent is especially absurd.
Why? It is certainly foreseeable that alerting the police while a robbery is still in progress could lead to a situation that is dangerous for store employees and customers.

So what? A person should only be liable for damages inflicted by his own actions, not for the criminal actions of unrelated third parties, even if said criminal actions are made more likely by the first party's lawful and justifiable actions. E.g., suppose someone draws a cartoon of Muhammad that provokes a bunch of Muslim extremists go berserk and starting killing people. The cartoonist is not liable for negligence, because the responsibility for the killings belongs 100% to the criminals who committed those crimes.
8.13.2009 9:48pm
Gabriel McCall (mail):
No, Steve, the complaint is not that the store procedure was negligent, but rather that the store manager was negligent through insufficient compliance with the procedure.


The complaint is based on the theory that the defendant was negligent in store procedure it had adopted to be followed during the course of such a robbery. The negligence alleged is thus the action taken once the holdup was in progress. The allegations are directed particularly to the silent alarm attached to the store safe.
...
Thus the plaintiff asserts that the triggering of the silent alarm was not in accordance with the instructions given employees, was not a prudent act, and did not show an exercise of due care for the safety of the customers.


The language that "The opening of the safe caused an alarm to sound" does not seem to indicate any option to decide not to trigger the alarm except by refusing to open the safe, so I don't see how any negligence can attach to the triggering of the alarm. An argument that the installation of the alarm was negligent would be a different matter, but that's not the complaint.
8.13.2009 10:03pm
DangerMouse:
But there was no choice available to the person who opened the safe not to trigger the alarm (as I read the opinion); the only way not to trigger it would have been to refuse to open the safe, which could just as easily have been construed as negligence. And if you're in a situation where all options available to you may lead to bad outcomes, I don't see how you can argue that the one chosen is negligent just because it did.

This case is very, very easy to understand. It was against Kroger, a big corporation.

Someone put their thumb on the scale and made a B.S. argument to hold the big evil corporation liable.

Every other person knows that the alarm was not a wrong action during the course of the robbery, because the alarm was installed previously and was a given. It wasn't an independent action that would be apparent to cause negligence, because it would have occurred once the safe was open.
8.13.2009 10:05pm
David Schwartz (mail):
Why? It is certainly foreseeable that alerting the police while a robbery is still in progress could lead to a situation that is dangerous for store employees and customers.
It is foreseeable that choosing to drive a car to Burger King could lead to a situation where you lose control of that car and crash into another car.

It is foreseeable the opening a bank creates a robbery target that could put its customers at risk in potential burglaries. If is foreseeable that starting a shipping company may allow some nut to send a bomb to someone and that bomb might kill them.

That the harm is foreseeable is certainly a requirement. But that it be fairly attributable to the action is another. Secretly alerting the police to a robbery in progress arguably makes things more safe, but I defy anyone to argue with a straight face that it is unreasonably dangerous.

There is simply no way a reasonable jury could argue that triggering a silent alarm that alerted the police to a robbery in progress was unreasonable. It's absurd beyond measure.
8.13.2009 11:01pm
Steve:
No, Steve, the complaint is not that the store procedure was negligent, but rather that the store manager was negligent through insufficient compliance with the procedure.

Sure, if you italicize that sentence and ignore the one right before it, you can argue that the plaintiff had a nonsensical theory, but I'm willing to give the court a little more credit than that.

If someone can make the case that there's some common-law principle that would prohibit the plaintiff from taking the case to the jury on a theory that it was negligent to have an alarm, then I'd like to hear what it is. Otherwise, if people just want to argue that the theory would have been valid, but there's an oddly-worded sentence that can be read to suggest that the plaintiff didn't advance that theory, there's not much there for me to engage with.

The store owner/manager can reasonably argue that he installed the alarm to help bring justice to any would-be robbers and that the deterrence effect of this would make his store (and other stores) safer overall because fewer robberies would be attempted.

That's a jury argument, not a basis for summary judgment.

So what? A person should only be liable for damages inflicted by his own actions, not for the criminal actions of unrelated third parties, even if said criminal actions are made more likely by the first party's lawful and justifiable actions.

This might or might not be a valid argument, but it's certainly not the law in any jurisdiction I'm familiar with. A property owner can certainly be held liable for the foreseeable criminal acts of a third party under common law - and the existence of the alarm makes it pretty clear that a robbery was foreseeable.

Also if the liability would stem from the store's communication to the police, then the First Amendment might preclude such liability.

This is a creative argument, at a minimum. Is there any case law to support it?
8.13.2009 11:11pm
David M. Nieporent (www):
If someone can make the case that there's some common-law principle that would prohibit the plaintiff from taking the case to the jury on a theory that it was negligent to have an alarm, then I'd like to hear what it is.
Sure. There's no duty to bystanders not to notify the police of a crime in progress.

Where did people get this notion that all one has to do is advance any crackpot theory and one is entitled to take it to a jury?
8.13.2009 11:16pm
Steve:
There is simply no way a reasonable jury could argue that triggering a silent alarm that alerted the police to a robbery in progress was unreasonable. It's absurd beyond measure.

And if the judge doesn't buy your argument that summary judgment should be granted because you personally find the theory absurd, do you have any actual authority to cite? Any actual common-law principles to point to?

There are obviously plenty of situations where shopowners have been found liable due to steps taken in response to a robbery. For example, if an employee tries to heroically stop the robbery and someone gets hurt, there may be liability. If an employee refuses to hand over cash and someone gets hurt, there may be liability. These fact patterns present fairly clear jury questions.

Alerting the police certainly strikes me as safer than trying to wrestle the gun out of the robber's hand, but since it's clearly less safe than simply cooperating with the robber and calling the police after the fact, a jury question is present just like in the other fact patterns.

For a judge to sit there and say that one type of noncooperation by the store employee might be unreasonable, but a different type of noncooperation must be reasonable as a matter of law, is a pure case of the judge substituting his judgment for that of the jury. Unless, of course, someone can show me that the common-law recognizes a privilege to act in this manner, which no one seems to be able to do.
8.13.2009 11:20pm
Steve:
There's no duty to bystanders not to notify the police of a crime in progress.

The plaintiff is not a "bystander," but a business invitee. Of course the owner has a duty not to subject a business invitee to an unreasonable danger.

It's certainly foreseeable that alerting the police could lead to a firefight or another type of situation that poses harm to the customers. Whether it's unreasonable to create that risk is a jury question.
8.13.2009 11:22pm
David M. Nieporent (www):
Ultimately, everything is "foreseeable." That doesn't mean every nutty claim is entitled to be heard by a jury.
8.13.2009 11:41pm
ll (mail):

Of course the owner has a duty not to subject a business invitee to an unreasonable danger.


And merely opening a business in area where they have been robberies of businesses foreseeably subjects a business invitee to unreasonable danger. Therefore, the business owner was negligent, unreasonably so, for having opened a business.
8.13.2009 11:43pm
ReaderY:
If the sound of the alarm had startled the robbers into shooting, would this plaintiff be asserting that not having a noisy alarm was negligent?
8.14.2009 12:07am
LarryA (mail) (www):
The store can always call the police after the robbery, but here they chose to adopt a policy which alerted the police during a robbery, obviously in hopes of preventing the robbery's successful completion. I might not agree with the theory, but a plaintiff can certainly argue that it was unreasonable for the store to value its money above the safety of its customers.
You’re neglecting the possibility that the robber might decide to eliminate witnesses, even if unprovoked. In that case the intervention of law enforcement would be the only hope, given the store rule against employee self-defense and the then-prohibition of concealed handguns carried by patrons.

The alarm was designed to alert law enforcement without the knowledge of the criminal. I note the plaintiff didn’t sue the cops for entering the store instead of waiting for the criminal outside. Kroger’s, of course, was the target with deeper pockets than the city, and less protection from liability.
Why? It is certainly foreseeable that alerting the police while a robbery is still in progress could lead to a situation that is dangerous for store employees and customers.
An armed robbery in progress is already “a situation that is dangerous for store employees and customers.” You could just as easily hold that not installing an alarm was negligent.
8.14.2009 12:26am
DangerMouse:
Ultimately, everything is "foreseeable." That doesn't mean every nutty claim is entitled to be heard by a jury.

Methinks people need to brush up on their torts. Some here need to read a little Learned Hand. Like the 10th Circuit...
8.14.2009 1:14am
einhverfr (mail) (www):
Steve

In other words, I see little difference between this theory and a theory that an employee unreasonably endangered customers by refusing to hand over money. I agree that both theories are problematic, but I don't see how they aren't jury questions. Obviously from the standpoint of the customer, whose primary concern is for his own safety, he prefers that store employees cooperate 100% with the robber and send him on his way - which includes giving him what he asks for, not triggering any alarms that might lead to a shootout with police, etc.


Of course all we are seeing is a short appellate ruling here. Presumably there is more to the trial courts ruling that might go into it. However, I think your viewpoint is a little off.

The robbers asked the store manager to open the safe. He did. The alarm was triggered. What in your view would have been an appropriate response, "I am sorry, I cant cooperate because my company might get sued if I do?" Maybe the manager is supposed to inform the robbers that the safe is alarmed and that it must be disarmed before he can proceed?

What is absurd about this is that, unlike liability for refusing to hand over money, this is liability for cooperating with the robbers and doing EXACTLY as they say without any delay.

The problem for me in this case is that if this is a matter for a jury, I am hard-pressed to think of a tort matter regarding a third-party-crime-gone-wrong that could be resolved via summary judgement.
8.14.2009 1:31am
Dilan Esper (mail) (www):
Danger:

Hand was writing about breach. This is a duty issue, not a breach issue.

Duty has traditionally been a matter of minimal foreseeability. Prof. Volokh, like many others, is implicitly criticizing this traditional



conception of duty. Of course, in many states, there is doctrinal room to do cost-benefit analysis of duty questions, but courts which do it are taking a key function of articulating the bounds of reasonable conduct away from juries who are in the best position to make such calls.
8.14.2009 2:43am
Doug Sundseth (mail):
While I'm not a lawyer, it is my understanding that there is a longstanding requirement in English law to raise a hue and cry when witnessing a crime. (Wikipedia references "the statute of Winchester, 13 Edw. I cc. 1 and 4, (1285)")

An alarm is just such a "hue and cry". (I leave aside the issue of a silent hue and cry, which seems, it must be said, a bit odd. 8-) )

Has the traditional duty to summon aid upon the witnessing of a crime been overridden by statute in Kansas? If there is no duty, it seems to me that voluntarily summoning aid would be one of the unenumerated traditional rights under Judge Bork's ink blot.

And failing that, I suspect I could make an argument based on petition for redress of grievance. I'm pretty sure that the store manager had a valid grievance that needed redress.
8.14.2009 2:59am
David Schwartz (mail):
Steve: No reasonable jury could possibly find that secretly informing the police of a robbery in progress is in any way negligent. It's simply impossible to advance that argument with a straight face.
8.14.2009 4:38am
Turk Turon (mail):
IANAL, but it seems to me that the plaintiff might have had a better case if the store manager, at the very outset of the robbery, had rushed to the office and opened the safe, knowing that it would trigger the silent alarm.

Some of these fershlugginger legal theories would seem to require that a business keep all of its cash in the trunk of a stolen car, kept idling in front of the business, as a convenience to the thieves. "Thanks for shopping at Kroger, and have a nice day!"
8.14.2009 7:18am
Ricardo (mail):
Steve, an element in your reasoning is that the presence of the police in an armed robbery situation may make the situation more dangerous. If that is indeed the case, there are two questions:

1. Could the store manager have reasonably foreseen that the presence of the police, alerted surreptitiously by the silent alarm, would make the situation more dangerous? Are store managers expected to be intimately familiar with police procedure to make a judgment call as to whether to alert the police silently or not?
2. If the answer to #1 is yes, presumably the police would have an even clearer idea that their presence would make the situation more dangerous -- a silent alarm can really only be interpreted as a situation where guys with guns are demanding the safe be opened for them. They, not the store manager, are the experts on how to respond to dangerous situations. So why does liability fall on the store and not on the police department?

I suspect the real-world answer to #2 is that the police department is generally immune to such lawsuits while the store has deep pockets. What is the legal answer, though? Certainly, this is very different from a manager who tries to play hero or who disobeys the robbers -- he did nothing observable to the robbers that changed the situation. The fact that the alarm was silent is critical here.
8.14.2009 8:35am
Ricardo (mail):
Some other questions come to mind also:

1. Did the store's insurance contract require it to have an alarmed safe? If not, it is easy to see that applying in another similar case. And if yes, would the next step be to sue the store's insurer for negligence for mandating the alarm?
2. Steve, suggestion that the store only cared about its own money is plausible (though not if it was insured) but not the only possibility. Having a bunch of guys waving around guns is a very dangerous situation. I suspect most police departments would rather be there on the scene rather than wait until after the robbers flee a safe distance -- you never know when someone might get trigger-happy. Again, if a police department is too incompetent to deal with an armed robbery in progress, why aren't they the ones being held liable?
8.14.2009 8:45am
David M. Nieporent (www):
Duty has traditionally been a matter of minimal foreseeability.
The law of negligence isn't old enough to be "traditionally" anything.

"Traditionally," duty arose from privity.

And again, as for foreseeability, I refer to the good Samaritan situation: walk by, see a stranger drowning, shrug and walk away. Foreseeable, yes. Duty, no. Negligent, no.
8.14.2009 9:18am
Gabriel McCall (mail):
Steve, you're still misreading the legal theory.


The complaint is based on the theory that the defendant was negligent in store procedure it had adopted to be followed during the course of such a robbery.


This does not mean that the procedure itself was negligent. It means that the procedure was negligently followed. "Negligent in store procedure" does not mean "negligent in creating the procedure", it means "negligent in the following of the procedure". All of the rest of the opinion makes it abundantly clear that the complaint is about the actions taken in the moment, not about the previous installation of the alarm.
8.14.2009 9:39am
David M. Nieporent (www):
The problem for me in this case is that if this is a matter for a jury, I am hard-pressed to think of a tort matter regarding a third-party-crime-gone-wrong that could be resolved via summary judgement.
Exactly. And once it gets to a jury, anything can happen; the plaintiff can win the lottery. I suspect for liberals that this is a feature rather than a bug. (Liberals generally oppose any sort of caps on recovery, even for noneconomic damages.)

Consider the broad outlines of what happened: {store robbery; customer shot by robber). No matter how it happened, one can craft an argument, based on foreseeability.

* The store shouldn't have triggered a silent alarm because it was foreseeable that police surprising the robber would lead to a shootout.
* The store shouldn't have triggered an audible alarm because it was foreseeable that police arriving at all would lead to a shootout.
* The store SHOULD have triggered an alarm (silent or audible) because it was foreseeable that the robber would shoot witnesses as he made his getaway.
* The store should have cooperated with the robber...
* The store shouldn't have cooperated with the robber because that would make it more likely it would be robbed...
* The store should have had a security guard...
* The store shouldn't have had a security guard...
* The store shouldn't accept cash, because this made it a robbery target.
* (As one person referenced above) The store shouldn't have opened in the first place, because it was foreseeable that a robbery might take place, and if a robbery took place, it was foreseeable that a customer would get hurt.

Since in hindsight a trial lawyer can always craft an argument that whatever the store happened to choose made the injury more likely, there's nothing a store can do -- in the doctrinal view of some of the posters above -- to avoid having a case go to the jury. They're trying to remove summary judgment from negligence law.
8.14.2009 9:51am
David Schwartz (mail):
No reasonable jury could find that triggering a silent alarm alerting the police to a burglary in progress was negligent. However, an unreasonable jury might so find. Despite the best efforts of the Plaintiff's bar, there is as yet no recognized right to roll the dice and hope for an unreasonable jury.

A similar issue occurs in product liability -- particularly with vehicles -- all the time. There's an accident and someone is injured, maybe the gas tank blows up. Well, if the gas tank had been placed elsewhere on the car, it wouldn't have blown up. But you have to put the gas tank *somewhere*.

To withstand summary judgment, there has to be some way a reasonable jury could find that the actions where negligent -- that is, they presented an unreasonable increase in danger.

People at a Kroger are not experts in crime response, nor are they expected or required to be. They do have to have reasonable procedures to follow in foreseeable crime events and they do have to act reasonably. There is no question whatsoever that they did so in this case. None at all. Period.
8.14.2009 10:16am
conlaw2 (mail):
The theory of the case appears to be that he was negligent in following store procedure.

He created the store procedure pamphlet. He also created the silent alarm, though not expressly written, the implicit procedure would be to use it in the event of a robbery, unless someone can point out another reason for one to exist.

It appears that there are two store procedures in the event of the robbery. One clearly implies that he should trigger a silent alarm. The other clearly states that employees should not raise verbal alarm. His actions did not directly contravene either of these procedures and directly complied with one of them.

The very theory presented by the court, seems to call for a summary judgment.
8.14.2009 10:46am
LouGots (mail):
My track shoes with the little ambulance logos have been hung up for years, but I still remember the words, "proximate cause."
8.14.2009 10:50am
David Schwartz (mail):
Since the circumstances in which the silent alarm was tripped were precisely those the police expected, the argument that the employee was negligent in triggering the alarm leads inexorably to the conclusion that the police were also negligent in responding to the alarm.

Is anyone who believes this case is reasonable willing to argue that it's reasonable for police to adopt a policy of ignoring silent burglary alarms from stores almost certainly occupied by customers?

If triggering the alarm presents an unreasonable risk, mustn't responding to it likewise do so?
8.14.2009 10:53am
DangerMouse:
They're trying to remove summary judgment from negligence law.

I still think it's more likely that this B.S. decision was done because it was against a big, evil corporation. Most bad decisions involve someone with their thumb on the scale favoring one side. That's what empathy on the bench will get you.
8.14.2009 10:54am
troll_dc2 (mail):

The standard of care owed to business invitees [under Kansas law] is ... one of “due care to keep the premises reasonably safe” for their use, but the proprietor is not an insurer of their safety.... The defendant had issued a pamphlet to its employees telling them what to do in the event of a holdup. The particular emphasis in the pamphlet was to do nothing to excite or startle the robbers. It stated in part that many robberies are by young persons who might start shooting if something unexpected should happen. The employees were warned particularly not to give any verbal alarm in the street because this would greatly increase the probability of injury. Thus the plaintiff asserts that the triggering of the silent alarm was not in accordance with the instructions given employees, was not a prudent act, and did not show an exercise of due care for the safety of the customers....


What the store created was the equivalent of an employee handbook. The theory of the case seems to be that the employer violated its own rules, which told employees what to do and what not to do. But the rules focused on employee behavior; they said nothing about what the employer would do on its own. The previously installed silent alarm was automatically triggered as a result of the employer's policy; it was not something in the power of any employee to prevent. As such, it was not covered in the instructions given to the employees.

As I read the quote, the plaintiff's theory is that the employees violated the employer's rules, but the claim is clearly based on what the employer had already done. No employee consicously triggered the alarm; no employee could have prevented the alarm from being activated. There was no employee negligence at all.
8.14.2009 11:30am
troll_dc2 (mail):
Not all courts agree with Kelly v. Kroger Co. Thus, the Oklahoma Supreme Court rejected the theory of the case in Horst v. Sirlin Stockade, Inc., 666 P.2d 1285 (1983), and said:


¶7 The appellants' third theory is that an agent of the appellee negligently provoked the killings by communicating in a hostile manner with the assailants. Appellants contend that the reasoning in Kelly v. Kroger Co., 484 F.2d 1362 (10th Cir. 1973) should be followed in this case. In Kelly, the court was concerned with the propriety of the actions of store employees during a holdup in which a customer was shot and killed by a robber after she was taken hostage when police responded to a silent alarm activated by an employee. The employer had issued to its employees a pamphlet which emphasized that during a holdup, they were to take no action which would excite or startle the robber. The court held that under the circumstances a cause of action did exist. Other courts have found that in such situations the issue of whether violence could have been avoided is speculative, and therefore not the basis of a cause of action. See Bennett v. Estate of Baker, 27 Ariz. App. 596, 557 P.2d 195 (1976); Boyd v. Racine Currency Exchange, Inc., 56 Ill.2d 95, 306 N.E.2d 39 (1973). We subscribe to the Bennett and Boyd doctrine. Appellants have failed to state a cause of action.


8.14.2009 11:37am
David M. Nieporent (www):
What the store created was the equivalent of an employee handbook. The theory of the case seems to be that the employer violated its own rules, which told employees what to do and what not to do. But the rules focused on employee behavior; they said nothing about what the employer would do on its own. The previously installed silent alarm was automatically triggered as a result of the employer's policy; it was not something in the power of any employee to prevent. As such, it was not covered in the instructions given to the employees.
But in any case, that misses the point. Trial lawyers love deviations from internal memoranda, but the logic makes no sense. Whether the employees' actions were reasonable depends not on whether they conformed to internal store policies, but whether the actions themselves were reasonable.
8.14.2009 11:42am
troll_dc2 (mail):
The case quoted should have been typed as Horst v. Sirloin Stockade, Inc.

I also have found a case, Helms v. Church's Fried Chicken, Inc., in which Kelly is cited for the proposition that "If plaintiff could present sufficient evidence to convince a jury that the employee, foreseeing the apparent risks and dangers of his action, acted unreasonably under the circumstances, increasing the hazard which ultimately caused the death, plaintiff would be entitled to recover." But the facts in that case were different.


... the Helmses went to Church's on 19 October 1981; that Richard went into the store, bought some food, and turned to leave; that one of Church's employees stated in a loud voice, "when you leave call the police we are being robbed"; that Richard was immediately assaulted by at least three robbers; that when Margaret Helms saw Richard Helms being attacked, she started out of the truck in the parking lot toward the store to help him; that Richard called out to Margaret to get in the truck and lock the door, but that she was attacked and robbed before she was able to do so; that Richard Helms was stabbed in the back, arm, thumb, both hands and eye, and that Margaret Helms was stabbed in the back, was bruised, suffered a concussion, and had her purse stolen.

8.14.2009 11:55am
einhverfr (mail) (www):
Steve:
You missed the relevant legal standard for review:

[Under Kansas law, it] is perhaps an aspect of “foreseeability,” not so much that a particular incident may occur, but once one is in progress, when the danger to the customer is evident.


I.e. the issue is what happens once the event is in progress, not whether a particular event might occur at some point in the abstract and possibly distant future.

There is NO allegation that installing the alarm was negligent, and such would be inconsistent with the standard in question.
8.14.2009 12:00pm
troll_dc2 (mail):

What the store created was the equivalent of an employee handbook. The theory of the case seems to be that the employer violated its own rules, which told employees what to do and what not to do. But the rules focused on employee behavior; they said nothing about what the employer would do on its own. The previously installed silent alarm was automatically triggered as a result of the employer's policy; it was not something in the power of any employee to prevent. As such, it was not covered in the instructions given to the employees.

----
But in any case, that misses the point. Trial lawyers love deviations from internal memoranda, but the logic makes no sense. Whether the employees' actions were reasonable depends not on whether they conformed to internal store policies, but whether the actions themselves were reasonable.



My analysis misses the point only if you want to impose liability and do not care how you do it. I would like to think that I have exposed the plaintiff's theory as logical nonsense. From the way the court phrased the plaintiff's argument, the store's instructions defined the concept of reasonableness, for why else would the instructions have been brought into the picture?

A decision likes this makes me hate plaintiffs' attorneys.
8.14.2009 12:02pm
David M. Nieporent (www):
My analysis misses the point only if you want to impose liability and do not care how you do it.
Obviously I don't "not care" how to impose liability. I'm saying that your analysis doesn't address the real problem with the plaintiff's approach -- the store's instructions should NOT define the concept of reasonableness -- not that your analysis itself is wrong.
8.14.2009 12:26pm
troll_dc2 (mail):
So we basically agree. I hope that Prof. Volokh will tell us a lot more after 16 September, which is the day that his class syllabus gives for a discussion of this decision. See here.

The Tenth Circuit panel that heard the case consisted of Judges Hill, Seth, and Holloway. Judge Seth wrote the opinion. The decision comes from a time when that court was generally regarded as the worst of the federal appeals courts. Nothing in the ruling cries out for that appraisal to be reconsidered.
8.14.2009 12:35pm
Dilan Esper (mail) (www):
Dacid nieperont:

Negligence law, accordinf to edward white's 'tort law in america: an intellectual history, is at least 150 years old and was available before then througfh an action for tresspass on the case. The relaxation of privity requirements surely expanded its reach, but buainess invitees always satisfied the privity requirements anyway.

We've had a century of duty as minimal foreseeability. We can't be taking cases away from juries just because right-wingers don't like the results.
8.14.2009 1:36pm
troll_dc2 (mail):
@ Dilan Esper:


We've had a century of duty as minimal foreseeability. We can't be taking cases away from juries just because right-wingers don't like the results.



Does that statement suggest that you agree with the Tenth Circuit? Are you suggesting that only right-wingers think that the decision was wrong?
8.14.2009 2:07pm
rick.felt:
Isn't there at least an implicit allegation here that the police did not handle their response to robbery properly? Faced with a silent alarm at a store, the police have many choices, ranging from charging in with guns blazing to going out for a donut. If the police are called and they act negligently, isn't that a superceding cause of the death?
8.14.2009 2:29pm
troll_dc2 (mail):

Isn't there at least an implicit allegation here that the police did not handle their response to robbery properly? Faced with a silent alarm at a store, the police have many choices, ranging from charging in with guns blazing to going out for a donut. If the police are called and they act negligently, isn't that a superceding cause of the death?


I have an even more fundamental question: Did a tort actually occur? What was the negligence? Installing a silent alarm? I do not think that a rational public policy would encourage businesses to do nothing at all when they are robbed. A silnt alarm is the least dangerous way of sommoning help. It is unfortunate that someone was killed here, but the blame goes somewhat to the police perhaps, though mostly to the shooter.
8.14.2009 2:41pm
Dilan Esper (mail) (www):
Troll:

I don't mind making summary judgment rulings on the basis of no breach as a matter of law, i.e., that no reasonable jury could find that the defendant did anything unreasonable. And one could certainly argue that activating the silent alarm isn't negligent as a matter of law.

I also don't mind making summary judgment rulings on the basis of minimal foreseeability, and again, I think there's a colorable argument that the risks of activating a silent alarm was unforeseeable as a matter of law.

But what I do mind is the type of reasoning, seen in this thread, that says we should make "no duty" rulings whenever we think that a jury might make an award that conservatives disagree with. The whole point of jury discretion is that sometimes they will make rulings that people don't agree with, but we place these matters in the jury's care because juries are in the best position to articulate norms of reasonable conduct based on community standards.

In the end, therefore, arguments that we should use duty law to take large swaths of cases away from duty are arguments that we shouldn't have a jury system at all in tort law and that judges should simply weigh the costs and benefits.

Gregory Keating and I published a rather long treatment of this in the Southern California Law Review a few years ago; I invite anyone interested in this topic to check it out.
8.14.2009 2:43pm
troll_dc2 (mail):

But what I do mind is the type of reasoning, seen in this thread, that says we should make "no duty" rulings whenever we think that a jury might make an award that conservatives disagree with. The whole point of jury discretion is that sometimes they will make rulings that people don't agree with, but we place these matters in the jury's care because juries are in the best position to articulate norms of reasonable conduct based on community standards.

In the end, therefore, arguments that we should use duty law to take large swaths of cases away from duty are arguments that we shouldn't have a jury system at all in tort law and that judges should simply weigh the costs and benefits.



Why do you inject conservatives and right-wingers into this discussion? I am neither and still hate the ruling without reservation.

Is it your position that the concept of "duty" is always entirely for the jury?

Is this statement by David M. Nieporent wrong?


There's no duty to bystanders not to notify the police of a crime in progress.

8.14.2009 3:01pm
Dilan Esper (mail) (www):
Troll:

"Duty" in tort law is a term of art. Basically, it is not case specific. You don't say "you have a duty to watch for cross-traffic before making a left turn at a crowded intersection" as a matter of negligence law. The duty you owe is to exercise reasonable care in the operation of your vehicle. The question of whether your left turn is unsafe is a matter of BREACH, determined by the duty, i.e., did you act reasonably?

The reason this is important is it is the division between judge and jury in negligence law. Judges determine whether you have a duty. Juries determine whether you breached it.

And sometimes a breach question is clear cut, and a court can issue summary judgment on the ground that no reasonable jury could find otherwise. That may be appropriate in the silent alarm situation.

But that's different from expanding the court's role by particularizing duty just because conservatives don't like some jury awards. The fact that juries sometimes do things that people don't like doesn't mean that we should take the questions away from them. If you start pouring all sorts of specifics into "duty", especially involving cost-benefit analyses and the like, you end up usurping the role of the jury in determining the issue of negligence. That happens to be a result many conservatives favor, but it isn't consistent with the traditions and history of negligence law, and it also is a very bad idea on its own merits because juries are actually better than judges at determining issues of community standards of reasonable conduct.
8.14.2009 3:17pm
einhverfr (mail) (www):
Steve:

For a judge to sit there and say that one type of noncooperation by the store employee might be unreasonable, but a different type of noncooperation must be reasonable as a matter of law, is a pure case of the judge substituting his judgment for that of the jury. Unless, of course, someone can show me that the common-law recognizes a privilege to act in this manner, which no one seems to be able to do.


But in this case, that isn't what is alleged. What is alleged was that a form of COOPERATING with the robbers was potentially unreasonable. Alternatives would have to have been at least in form non-cooperating, even informing the robbers that an alarm needed to be deactivated first.....

I don't think that tort law should be second-guessing folks' cooperation during an armed robbery under any circumstances.

The case cited in comments here where someone says "When you leave call the police because we are being robbed" is a non-cooperative act and is hence entirely severable from this issue.
8.14.2009 3:30pm
David M. Nieporent (www):
I also don't mind making summary judgment rulings on the basis of minimal foreseeability, and again, I think there's a colorable argument that the risks of activating a silent alarm was unforeseeable as a matter of law.
But "unforessable as a matter of law" is sophistry, a way of getting to the same result without using the phrase "no duty" because the latter offends your sensibilities. What makes it not foreseeable? Nothing; it certainly is foreseeable. And assuming arguendo that there's an issue there, why shouldn't that be a jury question rather than a judge question, under your framework? "Foreseeability" seems a lot more like a question of fact than "duty" does.

As for taking cases away from juries: once again, since when was it ever the law ("traditionally") that all you had to do was advance any theory of responsibility on the part of a defendant and you could get to a jury? You're the one trying to read one of the elements of negligence out of the law here.
8.14.2009 3:31pm
Dilan Esper (mail) (www):
But "unforessable as a matter of law" is sophistry, a way of getting to the same result without using the phrase "no duty" because the latter offends your sensibilities.

No, David. It's a way of containing the power of judges to prevent cases from going to juries by making it very difficult to grant summary judgment on duty issues.

The reality is, behind all the rhetoric about how this or that case is a "bad" result, what conservatives really want is for these cases not to get to juries because they don't trust their fellow citizens to make the "correct" calls on what constitutes reasonableness. As long as we are just controlling for outlier cases, allowing a court to come in and hold something truly unforeseeable is fine. But when it becomes more than that, it's dangerous.

As for taking cases away from juries: once again, since when was it ever the law ("traditionally") that all you had to do was advance any theory of responsibility on the part of a defendant and you could get to a jury?

The law has been that the jury, not the judge, gets to decide reasonable care for over a century, David. You are stacking the deck with this "any theory of responsibility" business, but the fact of the matter is, the jury gets to decide if the defendant is responsible, and that's a good thing. Conservatives just don't trust their fellow citizens to make decisions they agree with.
8.14.2009 3:37pm
einhverfr (mail) (www):
It seems to me a nice analogy might be the following case against various airlines whose planes were hijacked on 9/11.

Should the question of whether cooperation by flight staff with the hijackers created unreasonable safety issues for which the airlines should be liable (not only for the air deaths but the ground deaths as well) be something that goes to a jury? Under this standard it would seem have to go to a jury.
8.14.2009 3:44pm
troll_dc2 (mail):
Dilan, you concede that the Tenth Circuit may well have been wrong:


And sometimes a breach question is clear cut, and a court can issue summary judgment on the ground that no reasonable jury could find otherwise. That may be appropriate in the silent alarm situation.


So can you give an example to support your generalization?
8.14.2009 3:45pm
David Schwartz (mail):
The argument would be that phrasing it as whether there is "no duty to bystanders not to notify the police of a crime in progress" as a matter of law is an excuse to take the determination of negligence away from the jury.

In any cases where it is alleged someone negligently did X, you can phrase that as "as a matter of law, is there a duty not to do X" and turn any factual question into a legal one.
8.14.2009 3:49pm
David M. Nieporent (www):
The reality is, behind all the rhetoric about how this or that case is a "bad" result, what conservatives really want is for these cases not to get to juries because they don't trust their fellow citizens to make the "correct" calls on what constitutes reasonableness. As long as we are just controlling for outlier cases, allowing a court to come in and hold something truly unforeseeable is fine. But when it becomes more than that, it's dangerous.
Actually, Dilan, as long as we don't have "loser pays," I don't want these cases to go to juries even if I think those juries will make the correct calls.

But yes, sure, I think that people will not make correct calls on what constitutes reasonableness, when they're playing with someone else's money rather than their own.
8.14.2009 4:00pm
David M. Nieporent (www):
That is, I don't trust my "fellow citizens" at the ballot box, so I'm not sure why I should trust them any more in the jury box.
8.14.2009 4:01pm
David M. Nieporent (www):
The law has been that the jury, not the judge, gets to decide reasonable care for over a century, David.
You can find me a case from, say, 1905 where a store was held responsible because a robber injured one of its customers? Or even where such a case was allowed to go to a jury?
You are stacking the deck with this "any theory of responsibility" business,
I'm "stacking the deck" because you keep dodging the question, refusing to address it: under your view, every lawsuit involving a claim of negligence, at least beyond barking-at-the-moon-cia-is-beaming-signals-into-my-tinfoil, should go to a jury.

That is not quite the law yet, despite the best efforts of ATLA, and was certainly not "traditionally" the law, contrary to your claim. You yourself admit in your papers with Keating that you're trying to read duty out of the law entirely.
8.14.2009 4:10pm
David Drake:
David N. said:


[A]s long as we don't have "loser pays," I don't want these cases to go to juries even if I think those juries will make the correct calls.


Agree wholeheartedly with that. "Loser pays" would get rid of a whole lot of litigation. And not just frivolous complaints but frivolous defenses and counterclaims.
8.14.2009 4:29pm
Dilan Esper (mail) (www):
So can you give an example to support your generalization?

One example we used in our paper was Atkins v. Glens Falls, 424 N.E.2d 531 (N.Y. 1981), where the plaintiff's claim was that a baseball stadium owner was negligent in not building screening for foul balls that extended all around the field. This was non-negligent as a matter of law, because no reasonable jury could find that screening that extended to areas where foul balls did not generally land and where the patrons had more time to get out of the way and see the ball coming, and which was not customary in baseball stadium construction, was required as a matter of reasonable care.

The thing is, what you don't want to do is get courts in the business of saying "we are going to take cases away from juries and delineate ourselves what constitutes reasonable care in the construction of a baseball stadium". But it's perfectly OK to police the outlying cases, so long as it is restricted to situations where no reasonable jury truly could come to the opposite conclusion.
8.14.2009 5:58pm
Dilan Esper (mail) (www):
But yes, sure, I think that people will not make correct calls on what constitutes reasonableness, when they're playing with someone else's money rather than their own.

I can think of no better group of people to assess compensation for accidents than a group of my fellow citizens, based on standards of reasonableness that they can fully understand.

As for it being "other people's money", David, unless you believe that there should be no tort system whatsoever, there's always going to be someone awarding "other people's money" to another person. And since I assume you believe there should be a tort system, your criticism is meaningless, over-the-top rhetoric that you don't even believe.
8.14.2009 6:01pm
Dilan Esper (mail) (www):
You can find me a case from, say, 1905 where a store was held responsible because a robber injured one of its customers?

Not off the top of my head, but I can tell you that the universal legal rule back then was that businesses were liable to their business invitees for failing to exercise due care with respect to their safety. How this played out in specific cases was for juries to decide.
8.14.2009 6:03pm
Dilan Esper (mail) (www):
You yourself admit in your papers with Keating that you're trying to read duty out of the law entirely.

This is a complete and total lie and I defy you to find one statement where I have ever said that there should be no duty element to a negligence cause of action.
8.14.2009 6:04pm
David M. Nieporent (www):
This is a complete and total lie and I defy you to find one statement where I have ever said that there should be no duty element to a negligence cause of action.
An element that is automatically satisfied is not really an element at all. It would be like making "breathing" an element of the crime of armed robbery.
8.14.2009 6:20pm
Dilan Esper (mail) (www):
An element that is automatically satisfied is not really an element at all.

I defy you to show me a statement where I said that the duty element should "automatically" be satisfied.

Look, David, you need to tell the truth. If someone says that I am an advocate of a narrow, modest duty requirement that is relatively easy for plaintiffs to satisfy, I think that's perfectly fair. But that's not the same thing as claiming that I don't think there's any room for "no duty" rulings in tort cases. I have never said that and in fact endorsed several justifications for finding "no duty" in our paper.
8.14.2009 6:36pm

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