Is the Richards rule valid when a car is stolen from a parked vehicle?

Enders v. Apcoa, 55 Cal.App.3d 897, 905, 127 Cal.Rptr. 751, suggests that statistical data in the area of the automobile theft problem should, more properly, be addressed to the validity of the Richards rule. The data suggests that it is foreseeable to a reasonably prudent driver that if the keys are left in the ignition of an unattended vehicle, the risk of harm to innocent third persons from the reckless driving of a car thief is substantially increased.