Plaintiff was a customer at defendant's Burger King Restaurant when his iPhone was stolen by four other customers. He alleged the defendant was negligent in not providing "manned security" in the restaurant. The trial court dismissed the Complaint holding defendant owed no duty to protect plaintiff from the theft of his iPhone.

The First District affirmed. A landowner has no duty to protect others from criminal activities of third persons unless a special relationship exists between them. No legal duty based on a "special relationship" exists between a business invitee and a property owner. Therefore, the case was properly dismissed. Lewis v. Heartland Food Corporation, 2014 IL App (1st) 123303.