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No duty to accede to criminal demands should be imposed. The presence of guards and protective devices do not prevent armed robberies. The presence of armed guards may not prevent a criminal from either seizing the victim and using him as a hostage or putting a gun to his head. Nothing may prevent injury to the victim except a complete acquiescence in the robber's demand, and whether acquiescence would have spared the victim is, at best, speculative.
Piney Boyd brought a wrongful death action against Racine Currency Exchange and its clerk, Blanche Murphy, to recover damages for the death of Boyd’s decedent, a business invitee, during an attempted armed robbery. Murphy did not comply with the robber's demand for money after he threatened to kill Boyd’s decedent, and instead dropped to the floor. Boyd alleged several acts of negligence by defendants.
Did Racine Currency Exchange and its clerk, Blanche Murphy, owe Boyd’s decedent a duty to comply with the demands of the robber?
The court held that defendants did not owe to Boyd’s decedent a duty to comply with the demands of the robber. The court reasoned that nothing would have prevented injury to the decedent except a complete acquiescence to the robber's demands, and whether acquiescence would have spared the decedent was, at best, speculative. The court refused to grant criminals additional leverage to enforce their criminal demands, however harsh or unjust its decision might seem.