Williams v. Cunningham Drug Stores, Inc

In this case of first impression we are asked to determine whether a store owner must provide armed, visible security guards to protect customers from the criminal acts of third parties.

i

On May 4, 1979, plaintiff Willie Williams was shopping in a Cunningham drug store located in a high crime area of the City of Detroit. A plainclothes security guard was employed by the store, but on the day in question he was sick. Store personnel called the main office to request a substitute, but one was not sent.

While plaintiff was shopping, an armed robbery occurred. During the resulting confusion and…