In Minch v. Department of California Highway Patrol (2006) 140 Cal.App.4th 895, the Court of Appeal ruled that CHP officers owed no duty of care toward a tow truck operator who was hit by a passing motorist while walking toward his truck to retrieve a receipt book for business purposes. The court held that the CHP officers owed no duty of care because they did not direct the operator to stay at the accident site after he finished extracting a car from a ditch, nor did they tell him where to park his tow truck or where to walk. (Id. at p. 906.) There was no "special relationship" between the officers and the tow truck operator because the officers did not promise to protect the operator. The operator also could not reasonably have relied on them for protection because he knew, by the time the accident occurred, that they were no longer directing traffic around the site. (Id. at pp. 906-907.)