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:

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The court held that the store could be sued for negligence because there was a sufficient amount of criminal activity in the area to warrant warning customers. The store had a duty to provide adequate security to its customers and warn them of recognized dangers. The court found that the store breached this duty by failing to take reasonable steps to protect its customers from the foreseeable danger of criminal behavior in its parking lot.

In Erichsen V