Church owed its invitees no duty of care to aid them crossing a busy 5-lane street from the church’s parking lot to the church.  Though the fact that the injury occurred off premises is not determinative in itself, since placing the parking lot across the street increased the risk to invitees who parked there, a weighing of the Rowland/Biakanja factors shows that no duty of care should be imposed.  While injury to a pedestrian crossing the street was foreseeable and the injury was certain, the rest of the Rowland/Biakanja factors weighed against imposing a duty of care.  Importantly, the church could not control or implement safety precautions in the public street.  Its alleged lack of care had only an attenuated connection with plaintiff’s injury since both the pedestrian’s and the driver’s conduct intervened to create the accident.  The church’s conduct was not blameworthy, and the burden on it and other property owners would be great.

California Supreme Court (Liu, J.); November 13, 2017; 3 Cal.5th 1077.