California, United States of America
The following excerpt is from Jamison v. Mark C. Bloome Co., 112 Cal.App.3d 570, 169 Cal.Rptr. 399 (Cal. App. 1980):
Another post-Rowland decision applying the Restatement rule is Rogers v. Jones (1976) 56 Cal.App.3d 346, 128 Cal.Rptr. 404. A judgment upon a verdict in favor of plaintiff, a spectator injured in the stadium parking lot by another fan's assaultive behavior, was reversed. The fact that there had been prior instances of physical interference with a barrier, which apparently so annoyed the attacker as to provoke his attack, was held not sufficient to require defendant operator of the parking facility to anticipate the probability of such an attack. The court said (id., at p. 352, 128 Cal.Rptr. 404):
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