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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CEThe Nebraska high court's decision implies that for a store to be held liable for negligence due to a lack of security, there must be a foreseeable risk, which is often determined by the history of criminal activity in the area. If Erichsen had been the only person attacked (A), it suggests an unforeseeable, isolated incident, not negligence on the part of the store. The court also found that the level of criminal activity in the area did not warrant a duty for the store to warn customers (C), and that the high crime rate being common knowledge (E) further absolved the store of liability, as customers assumed the risk by choosing to shop there.

In Erichsen V