In the case before the Washington Court of Appeals, there was a “very narrow duty not to leave one’s motor vehicle running with the door open, on a roadway, while leaving the vehicle unguarded out of sight, when an unknown individual is nearby and it is foreseeable that the person might steal the vehicle.” Judge Bernard F. Veljacic wrote, finding a utility company owed a duty of care to a man seriously injured in a crash involving a stolen work vehicle.

       

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