Torts/Personal Injury
Nov. 12, 2025
Understanding the 'special circumstances' doctrine in stolen vehicle injury cases
In Murphy v. Pina, the Court of Appeal held that a body shop was not liable for injuries and death caused by a teenager who stole keys from the shop and crashed a rental car, finding that no "special circumstances" existed to impose a duty on the shop to control the actions of a would-be thief.
Michael E. Rubinstein
Law Office of Michael E. Rubinstein
433 N Camden Drive Suite 600
Beverly Hills , CA 90210
Phone: (213) 293-6075
Fax: (323) 400-4585
Email: Michael@rabbilawyer.com
Loyola Law School; Los Angeles CA
Michael is a Los Angeles-based personal injury and accident attorney.
A teenager roamed into an auto body shop owned by his grandmother. After swiping a set of car keys from behind the counter of the unattended shop, which contracted with Hertz Rent A Car, he and his friend got into an unlocked car parked in the back and went joyriding. They crashed, and his friend was injured. He later died of an overdose.
Is the body shop liable to the deceased friend's family? After all, it was easy for the te...
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$795 for an entire year!
Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)
Already a subscriber?
Sign In