In Erichsen v. No-Frills Supermarkets, a woman who was shopping was seriously injured by a robber in the parking lot. She sued the store claiming that its failure to provide adequate security was a breach of its duty to her. The Nebraska high court held that the store could:

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The court held that the store could be sued for negligence since the failure to provide adequate security was a breach of its duty to the patron. The fact that the incident occurred in the parking lot rather than inside the store did not absolve the store of liability.

In Erichsen V