Williams v. Cunningham Drug Stores, Inc., 429 Mich. 495 (1988) p180.

duty: landowners and occupiers

P was shopping when an armed robbery occurred. During the resulting confusion and panic, plaintiff ran out of the store, directly behind the fleeing robber. As the two men were outside, the robber turned and shot plaintiff [who by this time was outside the store].

P contended that D had breached its duty to exercise reasonably care for the safety of its patrons. Said D should have provided armed security guards.

Does a merchant have a duty to exercise reasonable care which includes providing armed, visible security guards to protect invitees from the criminal acts of the parties?

Cannot expect one to provide a degree of safety which is higher than that found in the community at large.

A merchant's duty of reasonable care does not include providing armed, visible security guards to deter criminal acts of third parties.

Duty to provide police protection (which is virtually what armed security guards are) is vested in the government by the constitution and statute. D cannot control incidence of crime in the community. Cannot require D to provide a safer environment on his premises than his invitees would encounter in the community at large. D is not an insurer of the safety of his invitees.