In the late 1980s, Missouri altered a longstanding common law rule and found that businesses sometimes owe a duty to their patrons to protect against or warn about criminal attacks by third parties.' This new rule generally applies when a business has experienced prior incidents that are reasonably recent and similar to the attack in question.3 In Stroot v. Taco Bell Corp., the Missouri Court of Appeals for the Eastern District of Missouri upheld a summary judgment entered in favor of a business for an attack that occurred in the business's parking lot even though the victim alleged that prior violent incidents had occurred in the parking lot and filed supporting affidavits.4 Perhaps Stroot represents a shift away from the modem trend of premises liability law and a return to a "take care of yourself' approach. Even more surprising is the court's apparent willingness to ignore the rescue doctrine in favor of protecting businesses from potential liability.

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