Cabral v. Ralphs Grocery Co., 51 Cal. 4th 764

Cabral's husband Adelelmo Cabral died following a collision with a Ralphs tractor-trailer that had stopped on the freeway shoulder for a nonemergency snack.
Horn, a Ralphs driver, stopped 16 feet from the outermost traffic lane in an area marked for emergency parking.
The area permitted emergency parking; the sign had existed since 2001 and Horn saw it.
The jury found Horn negligent and Cabral negligent, allocating 90% fault to Cabral and 10% to Horn; damages were awarded to Cabral's widow.
The Court of Appeal reversed, holding Ralphs owed no legal duty to Cabral; the Supreme Court granted review.
The Court holds that there is a general duty of reasonable care under Civ. Code §1714 and declines a categorical no-duty rule for stopping alongside freeways.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is there a duty of ordinary care to avoid harm when stopping on the freeway shoulder for nonemergency reasons?	Cabral argues Ralphs driver owed a duty of ordinary care to other freeway users.	Ralphs argues no duty should extend to stopping for nonemergency purposes on a shoulder.	No categorical exemption; duty exists.
Do Rowland factors justify immunizing drivers from liability for stopping alongside freeways for discretionary purposes?	Rowland factors support imposing duty to exercise ordinary care.	Rowland factors justify creating a no-duty rule.	No public policy-based exemption; general duty applies.
Was the evidence sufficient to support causation between Horn's stop and Cabral's death?	Horn's stop was a substantial factor in causing the collision.	Even if negligent, causation or policy could negate liability.	Substantial evidence supports causation; no superseding cause per se.
Do public policy considerations justify immunizing stopping on the shoulder from liability?	Public policy does not justify immunity given foreseeability and corrective incentives.	Immunity would promote road safety and minimize burdens on drivers.	No clear public policy supporting an exemption.

Rowland v. Christian, 69 Cal.2d 108 (Cal. 1968) (established multi-factor duty considerations; not a blanket exemption)
Ballard v. Uribe, 41 Cal.3d 564 (Cal. 1986) (foreseeability and policy analysis applied to duty; cautions against overbroad exemptions)
Lugtu v. California Highway Patrol, 26 Cal.4th 703 (Cal. 2001) (duty analysis and role of jury in determining negligence under regime of duty)
Richards v. Stanley, 43 Cal.2d 60 (Cal. 1954) (special circumstances informs duty; distinguishes ordinary third‑party risk from protected duty)
Bryant v. Glastetter, 32 Cal.App.4th 770 (Cal. App. 1995) (foreseeability/connection impact on duty analysis; not controlling here but referenced for proximity of risk)
Capolungo v. Bondi, 179 Cal.App.3d 346 (Cal. App. 1986) (causation/parking ordinance considerations; distinguishable from freeway emergency context)
Whitton v. State of California, 98 Cal.App.3d 235 (Cal. App. 1979) (duty vs. breach; discusses emergency stopping context on freeway shoulder)
Parsons v. Crown Disposal Co., 15 Cal.4th 456 (Cal. 1997) ( Rowland framework for duty analysis; balancing factors)