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Missouri business owners owe no general duty to protect against third-party criminal acts.

The Missouri Court of Appeals has affirmed the general rule in Missouri that a business owner/operator has no duty to protect invitees from the criminal acts of third-parties. One hot summer day, the plaintiff in M.B. v. Live Nation Worldwide, Inc., et al. attended a concert at the Hollywood Casino Amphitheater, operated by Live Nation. She arrived at the concert with a male acquaintance (A.R.) and suspected that she had been given a date rape drug at some point during the evening. M.B. became sick and asked A.R. to get his truck so they could leave the concert early. While A.R. retrieved his truck, M.B. received medical attention from an on-site nurse. The nurse recalled that M.B. was overheated and had overconsumed alcohol. She was treated with air conditioning, a cold towel and water. The nurse treating M.B. determined she was fit to leave the concert and M.B. signed herself out of treatment and waited at a nearby security tent for A.R. When A.R. arrived at the front gate, security personnel asked M.B. if her friend drove a truck. M.B. said yes and proceeded to get into A.R.’s truck. M.B. alleged that A.R. raped her after they returned to M.B.’s apartment. 

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