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4333 REVIEW DENIED In the absence of special circumstances, one who leaves ignition keys in a motor vehicle has no duty to a plaintiff who is injured by a thief who has stolen the vehicle; the fact that there were two prior car thefts from the storage lot of defendant’s repair shop was not a special circumstance that would result in the imposition of such a duty, particularly in view of the facts that defendant built a fence around the lot and installed motion detectors, alarms, and video cameras, in spite of which a thief managed to enter and steal a truck by driving it through the fence.CitationMAY v NINE PLUS (Stolen Pickup) 143 CA4 1538 [See: Richards v Stanley 43 C2 60; Ballard v Uribe 41 C3 564; Avis v Superior Court 12 CA4 221, T/AT 3/93; Thing v LaChusa 48 C3 644]
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