In Marshall v. Burger King Corp., 222 Ill. 2d 422, 856 N.E.2d 1048, 305 Ill. Dec. 897 (2006), a driver backed into a lamppost and then her car became airborne when the accelerator stuck, and the car crashed through the half-wall and windows of a Burger King restaurant, fatally injuring the decedent, who was eating inside the restaurant. Marshall, 222 Ill. 2d at 425. The plaintiff sued Burger King and others, alleging that the defendants did not exercise due care in designing, constructing, and maintaining the restaurant and that their failure to do so proximately caused the decedent's death. Marshall, 222 Ill. 2d at 424-25. The defendants filed a motion to dismiss the complaint and argued that they owed no duty to the decedent. Marshall, 222 Ill. 2d at 427. The trial court granted the motion to dismiss, and this court reversed and remanded for further proceedings. Marshall, 222 Ill. 2d at 427. Our supreme court granted leave to appeal. The defendants argued that the possibility of an out-of-control car penetrating the restaurant and injuring the decedent was not reasonably foreseeable, and they criticized the appellate court for determining that a duty existed without addressing the four factors. Marshall, 222 Ill. 2d at 431. Our supreme court began its analysis by saying that the scope of its inquiry was limited to whether the defendants, as owners and operators of a business, owed a duty to the decedent, who was their business invitee. Marshall, 222 Ill. 2d at 433. Thus, the discussion in Marshall commenced with a focus on the relationship between the defendants and the decedent. "The touchstone of this court's duty analysis is to ask whether a plaintiff and a defendant stood in such a relationship to one another that the law imposed upon the defendant an obligation of reasonable conduct for the benefit of the plaintiff. This court often discusses the policy considerations that inform this inquiry in terms of four factors: (1) the reasonable foreseeability of the injury; (2) the likelihood of the injury; (3) the magnitude of the burden of guarding against the injury; (4) the consequences of placing that burden on the defendant. Marshall, 222 Ill. 2d at 436-37. The court next said that the defendants relied extensively on the four factors in arguing that they owed no duty, while the plaintiff emphasized the relationship plus the four factors in arguing that a duty existed. Marshall, 222 Ill. 2d at 437. At this point, the court stated: "As we shall explain, the special relationship between a business invitor and invitee does indeed give rise to a duty of reasonable care that is applicable to this case, and the factors relied on by defendants do not support the creation of an exemption from that duty." Marshall, 222 Ill. 2d at 437. The court then moved into a discussion of the Restatement (Second) of Torts and said that the general rule articulated in section 314A of the Restatement, "and long recognized by this court, is that certain special relationships may give rise to an affirmative duty to aid or protect another against unreasonable risk of physical harm." Marshall, 222 Ill. 2d at 438. The court said that one such special relationship was between business invitor and invitee. Marshall, 222 Ill. 2d at 438-39. The court concluded that a duty existed in Marshall because "defendants' business, a restaurant, is undoubtedly of such a nature that it places defendants in a special relationship with their customers, as it is an establishment open to the general public for business purposes." Marshall, 222 Ill. 2d at 440. Our supreme court next addressed the policy considerations behind finding that a duty existed, beginning with the following context: "Thus, in determining whether a plaintiff and a defendant stand in such a relationship to one another that the law imposes an obligation of reasonable conduct on the defendant for the benefit of the plaintiff citation, we are confronted with a decision of policy. In the case of a business invitee harmed by the negligent act of a third person, the policy justifying the business invitor's duty of reasonable care is related to the affirmative action the invitor takes in opening his business to the public and to the potential for harm that a business open to the public poses." Marshall, 222 Ill. 2d at 441. The court then moved into a discussion of the four factors, finding that the accident was reasonably foreseeable, that the likelihood of such an occurrence was high, and that the burden of guarding against the injury and the consequences of placing that burden on the defendants were speculative. Marshall, 222 Ill. 2d at 442. The court observed that the defendants were erroneously conflating duty with breach of duty and said: "Thus, the issue in this case is not whether defendants had a duty to install protective poles, or a duty to prevent a car from entering the restaurant, or some such other fact-specific formulation. Because of the special relationship between defendants and the decedent, they owed the decedent a duty of reasonable care." Marshall, 222 Ill. 2d at 443. In sum, the Marshall court held that the defendants' duty arose from their relationship with the decedent, and it addressed the four factors only in considering whether to create an exemption from that duty.