Does a business owe a duty to protect customers from third-party vehicle crashes? Schofield v. Starbucks Corporation Explained

In Schofield v. Starbucks Corporation, the Utah Court of Appeals clarified the important distinction between duty and breach in business liability cases involving third-party harm. The case arose from a tragic incident where a pickup truck experiencing a medical emergency crashed through a Starbucks outdoor seating area, killing customer Joslyn Schofield.

Background and Facts

Schofield was seated in an outdoor seating area at a Millcreek Starbucks when a driver having a medical episode lost control of his pickup truck. The truck traveled across five lanes of Highland Drive at 29 mph and crashed into the seating area, causing fatal injuries. The seating area had no protective barriers between it and the adjacent street or parking lot. Schofield’s estate sued Starbucks for negligence, premises liability, and wrongful death, alleging the company failed to exercise reasonable care to protect patrons from vehicle crashes.

Key Legal Issues

The central issue was whether Starbucks owed a legal duty to protect customers from third-party vehicle crashes. The district court dismissed the case, ruling that Starbucks had “no duty” to protect against such unforeseeable events, relying heavily on language from Dwiggins v. Morgan Jewelers suggesting businesses ordinarily owe no duty until they know third-party acts are likely to occur.

Court’s Analysis and Holding

The Court of Appeals reversed, emphasizing that duty is a categorical legal question while breach and proximate cause are case-specific factual questions. The court explained that the business-invitee duty of reasonable care is well-established in Utah law. Since Starbucks operated a business open to the public and Schofield was its customer, Starbucks unquestionably owed her a duty of reasonable care. The court reinterpreted Dwiggins as a breach case rather than a duty case, noting that arguments about foreseeability and specific protective measures belong in breach analysis.

Practice Implications

This decision reinforces that Utah courts analyze duty categorically rather than case-specifically. Practitioners defending businesses should focus on whether plaintiffs have alleged facts sufficient to invoke an established duty, rather than arguing case-specific foreseeability at the motion to dismiss stage. The court explicitly stated that defendants may still obtain early dismissal in appropriate cases, but foreseeability arguments are better suited for summary judgment proceedings after discovery develops the factual record.