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CRAIG v. WASHINGTON TRUST BANK

No. 17028-4-III.

976 P.2d 126 (1999)

94 Wash.App. 820

Jennifer CRAIG, Appellant, v. WASHINGTON TRUST BANK, Respondent.

Court of Appeals of Washington, Division 3, Panel Five.

Publication Ordered March 23, 1999.

Attorney(s) appearing for the Case

Charles T. Conrad, Spokane, Charles E. Rohr Jr., Spokane, for Appellant.

Michael A. Maurer, Michael A. Roozekrans, Spokane, for Respondent.

Sherrie Wright, Spokane, Pro Se.

BROWN, J.

Jennifer Craig, a janitor working for an independent contractor, sued Washington Trust Bank (Bank) for negligence arising from a third person criminal assault occurring one night as she left the Bank to empty trash. The trial court granted summary judgment against her. Generally, no duty exists to protect others from the criminal acts of third persons. However, some special relationships may give rise to exceptions to this general rule. We agree with the...

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