In Cabral v. Ralph's Grocery Co. (2011) 51 Cal.4th 764, a widow sued for the wrongful death of her husband. She was awarded $480,000 for economic damages and $4.33 million for noneconomic damages; the damages were reduced by 90 percent, however, because the jury found the decedent to be 90 percent at fault. (Id. at p. 770.) The case presented an issue of duty; it did not present an issue of excessive damages. The Supreme Court summarized the so-called Rowland factors for determining whether a duty of care exists: "In the Rowland decision, this court identified several considerations that, when balanced together, may justify a departure from the fundamental principle embodied in Civil Code section 1714: 'the foreseeability of harm to the plaintiff, the degree of certainty that the plaintiff suffered injury, the closeness of the connection between the defendant's conduct and the injury suffered, the moral blame attached to the defendant's conduct, the policy of preventing future harm, the extent of the burden to the defendant and consequences to the community of imposing a duty to exercise care with resulting liability for breach, and the availability, cost and prevalence of insurance for the risk involved.' " (Cabral, supra, 51 Cal.4th at p. 771.) In Cabral, the California Supreme Court stressed, "In the absence of a statutory provision establishing an exception to the general rule of Civil Code section 1714, courts should create one only where 'clearly supported by public policy.' " (Cabral, supra, 51 Cal.4th at p. 771.)