## Facts

- John Boyd entered Racine Currency Exchange in Chicago to transact business as a customer and business invitee.
- An armed robber entered, held Boyd at gunpoint, and threatened to kill him unless the teller, Blanche Murphy, gave him money or opened a door.
- Murphy was behind a bulletproof glass window and partition; she did not comply with the robber’s demands and instead fell to the floor.
- The robber shot Boyd in the head, killing him.
- Boyd’s widow sued the currency exchange and Murphy for wrongful death, alleging negligence based on refusal to comply, an undisclosed policy of protecting money “at all costs,” and failure to instruct or employ competent personnel for robbery situations.

## Issues

1. Whether a business proprietor and its employee owe a duty to an invitee to comply with an armed robber’s demands when refusal may increase the risk of harm to the invitee.
2. Whether allegations of an internal “protect the money at all costs” policy can establish actionable negligence absent a duty to comply with criminal demands.
3. Whether failure to instruct or train employees on responding to an armed robbery states a negligence claim when the asserted “proper” response is compliance with the robber’s demands.

## Decision

- The Illinois Supreme Court reversed the appellate court and affirmed the circuit court’s dismissal for failure to state a cause of action.
- The court held defendants owed no duty to comply with the robber’s demands to protect Boyd.
- Because no such duty existed, the internal-policy and failure-to-train allegations did not state an independent basis for liability.

## Legal Principles

- Negligence liability requires a legally recognized duty; the general duty of reasonable care toward business invitees does not extend to an obligation to surrender property in response to criminal threats.
- Courts may limit proposed duties based on policy considerations, including the speculative safety benefits of compliance, the burden and indeterminacy of a rule requiring immediate crisis judgments, and the risk of incentivizing hostage-taking.
- Allegations of negligent training or internal policy fail where they depend on an underlying duty the law does not impose.

## Conclusion

A business is not negligent for refusing to comply with an armed robber’s demands, even when a customer is threatened, and derivative theories premised on an asserted duty to comply—such as undisclosed policies or inadequate training—do not state a claim without a legally recognized duty.


Boyd v. Racine Currency Exch., Inc., 56 Ill. 2d 95, 306 N.E.2d 39 (Ill. 1973)