Taco Bell, Inc. v. Lannon

A Taco Bell, Inc. (defendant) restaurant located in a dangerous neighborhood of Denver was robbed 10 times over the course of three years. Just two days after the most recent robbery, John Lannon (plaintiff) entered the restaurant, only to find that he was interrupting an armed robbery. Lannon ran out the door into the parking lot, and one of the robbers shot after him, injuring Lannon’s ring finger. Lannon sued Taco Bell for negligence. Lannon alleged that Taco Bell had acted negligently by failing to take adequate measures to protect customers from the foreseeable criminal acts of third parties. At trial, police officers testified regarding security measures that Taco Bell might have taken to reduce the likelihood of armed robberies, such as hiring security guards. Taco Bell moved for a directed verdict, arguing that it had no duty to protect customers from the criminal acts of third parties. The trial court denied Taco Bell’s motion. The jury found in favor of Lannon, awarding him $40,000 in damages. Taco Bell appealed. The court of appeals held, among other things, that the evidence established a duty for Taco Bell to take reasonable measures to prevent or deter reasonably foreseeable acts, such as armed robberies. Both Taco Bell and Lannon petitioned for certiorari. The supreme court granted certiorari on the issue of whether a fast food restaurant in a high crime area has a legal duty to take measures to protect customers from criminal acts.