Victims of car accident cannot sue owner of car stolen from driveway

The family of Angela Readus sued Michelle Rogers claiming negligence.  The facts were not in dispute.  Rogers started her car in the morning and then returned to the house to gather her kids to go to school.  The car was stolen while it was warming up in her gated (but not locked) back yard.  The perpetrator then caused a motor vehicle collision which killed Ms. Readus.  Her family argued that Rogers bore some responsibility for the collision because Rogers had left her car running unattended in a neighborhood where there was a history of car thefts.  The Court rejected this theory and dismissed the wrongful death claim against Rogers.